New Hazardous Waste Manifest

September 5, 2006 Effective Date

On March 4, 2005, U.S. EPA published final rules revising the hazardous waste manifest. The revisions were effective September 5, 2006. Hazardous waste generators should begin using the new manifest forms after September 4, 2006.

Nationwide Standardization

The new manifest rule standardizes the appearance and content of the manifest form and continuation sheet (Forms 8700-22 and 22a). In the process, a number of data fields have been removed from the form (e.g., state ID number) and several have been added (e.g., waste management codes, which are to be entered by the receiving facility). All states are required to use the new form and all existing “state optional” fields will be eliminated. Manifest numbers will now be pre-printed on the form.

Where to Get the New Form

The new rule also increases the number of sources for obtaining manifest forms. Sources must register with U.S. EPA and follow strict printing requirements. U.S. EPA will not be a source for the new form. States may register as a source, but may not adopt rules designating the state as the exclusive source. Companies may also register and print their own forms.

U.S. EPA will maintain a list of registered sources on their web site at: http://www.epa.gov/epaoswer/hazwaste/gener/manifest/registry/index.htm.

A copy of the new form is also available for review only at: http://www.epa.gov/epaoswer/hazwaste/gener/manifest/forms.htm.

For more information, please contact, David Strayer or Howard Zwirn at 800.229.1443 or via e-mail at dcs@paynefirm.com or hjz@paynefirm.com.