Hazardous Waste (HW) Return Manifests

And what to do if you do not get them from your TSDF


Any generator of hazardous waste is required to keep a copy of each signed manifest for at least 3 years from the date the waste was accepted by the initial transporter (40 CFR 262.40). However, generators do not always receive a copy of the manifest with a signature (handwritten or electronic) of the owner/operator of the treatment storage and disposal facility (TSDF). Below are the necessary actions for generators (based on generator status) if this occurs.

Large Quantity Generators (LQG):

  • If a LQG has not received a copy of a signed manifest from a TSDF within 35 days of the date the waste was accepted by the initial transporter, the generator must contact the transporter or owner/operator of the TSDF for either the signed return manifest or a determination of the status of the waste.
  • If a LQG has not received a signed return manifest within 45 days of the initial transportation of the waste, the generator must submit an exception report to the Commissioner (If a manifest is received within 45 days of the initial transportation of the waste, an exception report does not need to be submitted).
  • The exception report must be submitted within 5 days after the 45-day period expires (50 days after the initial transportation of the waste).
  • Within 15 days after receiving a manifest that was the subject of an exception report, a notification must be submitted that the manifest has been received.

Small Quantity Generators (SQG):

  • If a SQG has not received a copy of a signed manifest from the TSDF within 60 days of the date the waste was accepted by the initial transporter, the generator must submit a copy of the manifest with an indication that the generator has not received delivery confirmation.
  • The submission only needs to be a typed or handwritten note saying that the return manifest was not received.

For more information about HW return manifests or any questions related to EHS compliance, free to reach out to Carter Venable at Carter@StevensEHS.com to get started


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