Chapter 1: The Hazardous Waste Manifest System and Who Needs to Use the Manifest Form and General Information
General Manifest Information:
The Uniform Hazardous Waste Manifest form is a chain-of-custody form used to track the generation, transportation and receipt of hazardous waste. As of September 5, 2006, the entire country uses the same form. Some states, such as New York, have special rules for completing the form.
The Manifest form includes information on the Generator, Transporter and Treatment, Storage and Disposal Facility (TSDF), the hazardous waste type, hazardous waste quantity, and how it will be managed. Using this form ensures proper hazardous waste disposal.
The manifest form is made of six attached sheets, an original top sheet and five copies beneath. All sheets have the same pre-printed Manifest Tracking Number in the upper right-hand corner. This allows for sheet tracking in electronic data systems. One unique Manifest Tracking Number is associated with one waste shipment. The six sheets are marked for distribution as follows:
- Sheet 1: Designated Facility to Destination State
- Sheet 2: Designated Facility to Generator State
- Sheet 3: Designated Facility to Generator
- Sheet 4: Designated Facility's Copy
- Sheet 5: Transporter's Copy
- Sheet 6: Generator's Initial Copy
Note: "Designated Facility" and "Treatment, Storage and Disposal Facility" (TSDF) are the same.
NYS requires the Generator to submit a copy of the Manifest form to DEC, postmarked within 10 calendar days of shipping hazardous waste. This means that the Generator may need to make a photocopy for submission. Generators must ensure that the copy is typed or handwritten within the proper boxes, not too light or dark and not misaligned. Highlighting is discouraged. If both the Generator and TSDF are located in NYS, then the Generator may use Sheet 2 for their submission to DEC. The TSDF must submit a copy of the manifest form to DEC, postmarked within 10 calendar days of waste receipt.
At the DEC, staff involved with hazardous waste manifesting include: facility inspectors, administrative staff, chemists, attorneys, environmental conservation officers, regulation writers, computer system developers and technical staff.
Record Keeping:
Generators, Transporters and TSDFs are required to keep copies of all hazardous waste manifest forms for three years after shipping. Occasionally, a Generator or TSDF may receive a letter from NYS DEC requesting a copy of a manifest form. Companies receiving these requests must mail a response within five business days.
Universal Wastes:
Universal Waste is a special category of hazardous waste that has different regulatory requirements. Universal Wastes include batteries, pesticides, lamps and mercury containing equipment. For further information on managing mercury containing equipment, see www.dec.ny.gov/chemical/8514.html. A hazardous waste manifest form is not required by NYS DEC when shipping Universal Waste. However, the Generator's business partners or another state may request that this form be used. If using a hazardous waste manifest form to ship Universal Waste, enter UNIVERSAL WASTE in Box 9b of the manifest form.
Universal Waste quantities do not apply when determining a Generator's status. See Chapter 2 for further information on Generator status.
Generators shipping 500 pounds or more of Universal Waste need to use a Part 364 permitted transporter.
Recycled Hazardous Wastes:
Hazardous wastes that are shipped to a recycler still need to be manifested.
Why Track Hazardous Waste Shipments?
- It is the Generator's waste FOREVER
- Ensures a cleaner environment and proper management of hazardous waste
- The Manifest is the source of data for Annual Reporting, Special Assessments, Regulatory Fees and Surcharge
- Avoid enforcement proceedings
- Required by federal law and State regulations
Choose Business Partners Wisely! Transporters and TSDFs:
It is the Generator's responsibility to ensure that the companies they do business with are properly permitted. Transporters need to have a Part 364 Waste Transporter Permit AND the permit must allow them to transport the specific waste the Generator makes to a specific Treatment, Storage and Disposal Facility. As all Transporters are required to keep a copy of their permit with them on every vehicle, the permit should be available for the Generator to review. Further information on the Part 364 waste transporter program may be found at www.dec.ny.gov/chemical/8483.html. Similarly, the TSDF needs to have a Part 373 Hazardous Waste Management Facilities permit. NYS DEC employees inspect hazardous waste management facilities. To review a facility's inspection report contact the Facility and Compliance Section (518) 402-8792.
Who Needs To Use The Hazardous Waste Manifest Form?
In regulation there are three defined Generator categories, or statuses. They are Conditionally Exempt Small Quantity Generators (CESQG), Small Quantity Generators (SQG) and Large Quantity Generators (LQG). SQG and LQG companies are required to use the Hazardous Waste Manifest form in New York. CESQG companies are not required to use the Manifest form in New York. Please see Chapter 2 Generator Status to determine your status. Transporters and TSDFs also use this form.
Should a CESQG get an EPA RCRA ID Number and use the Hazardous Waste Manifest form anyway?
While getting an EPA RCRA ID and using the Manifest form are not required by New York for a CESQG company, they may choose to use these items to more effectively track their hazardous waste shipments. Further, a Generator's business partners (Transporters and TSDFs) and States other than New York may require their use. If a Manifest form is used by a CESQG, they are not required to submit the form to NYS DEC.
Please see Part 371.1(f) (link leaves DEC's website) for the definition, regulatory requirements and regulatory exemptions for CESQG's.
Submitting Hazardous Waste Manifest Forms
Manifest forms should be mailed to:
NYSDEC
Division of Materials Management
Waste Transport and State Assistance Section
625 Broadway
Albany, NY 12233-7252.
Provide legible copies and make a good copy if needed.
Please Do Not Fax Forms.
Any questions concerning hazardous waste manifesting may be emailed to manifest@dec.ny.gov, or by phone at (518) 402-8730.
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