Arkansas Hazardous Waste Manifests

Programs Branch

Tamara Almand, Program Branch Manager - (501) 683-0069


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Background

The Hazardous Waste Management program is designed to manage hazardous waste from “cradle-to-grave”, by tracking waste from its point of generation to its ultimate disposal. The required hazardous waste shipping paper, the Uniform Hazardous Waste Manifest (EPA Form 8700-22), is the key to this objective.

Each time hazardous waste is transferred during shipment; e.g., from the generator to a transporter, or from a transporter to the designated disposal facility; the Manifest must be signed to acknowledge receipt of the waste. Once the waste is delivered to the designated facility, the operator of that facility sends a copy of the manifest back to the generator. This system ensures that the generator has documentation that the hazardous waste has been received at its ultimate destination. Through the use of a manifest, this Department can track the movement of hazardous waste from the point of generation to the point of its ultimate treatment, storage, or disposal.

Effective September 5, 2006, all hazardous waste shipments across the nation are required to be accompanied by the national Uniform Hazardous Waste Manifest (EPA Form 8700-22), which will be printed and distributed by companies registered with EPA.

When Uniform Manifests are Required

Arkansas requires the use of the national Uniform Hazardous Waste Manifest for all hazardous waste shipments into, within, and out of the State.

If you have more than four line items of waste, you must use a manifest continuation sheet. Each continuation sheet must have the accompanying manifest document number on it.

Where to Get Uniform Manifests

Generators obtain EPA Uniform Hazardous Waste Manifests from organizations approved by the EPA Manifest Registry to print the RCRA hazardous waste manifest. The TSD Facilities or Transporters will often provide manifests as a service to their customers.

State-Specific Manifest Requirements

  • Arkansas does not require submission of the state copy of the manifest to ADEQ.
  • Arkansas does not have state-specific waste codes.
  • Transporters must obtain a permit through the Arkansas Highway and Transportation Department. The permit number does not have to be recorded on the manifest.
  • CESQGs are required to use a Uniform Hazardous Waste Manifest for all shipments of hazardous waste into, within, or out of Arkansas.

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Completing the Uniform Hazardous Waste Manifest

Line-by-line Manifest Instructions are available for completing Uniform Hazardous Waste Manifests. An example of the Uniform Hazardous Waste Manifest is available and also one for the continuation page.

Resource Conservation and Recovery Act (RCRA) manifests contain the:

  • Name and EPA identification number of the generator, the transporter(s), and the facility where the waste is to be treated, stored, or disposed (TSDF);
  • DOT description of the waste being transported;
  • Quantities of the waste being transported; and
  • Address of the treatment, storage, or disposal facility to which the generator is sending waste (called the designated facility).

Each manifest contains a certification that:

  • The generator has in place a program to reduce the volume and toxicity of the waste to the degree economically practicable, as determined by the generator.

Hints for Successfully Manifesting Your Wastes

Verify the generator, transporter, and TSDF EPA identification numbers to make sure they are correct, and that you haven’t transposed any of the numbers.

  • Ensure that the EPA identification number matches the site address on your RCRA Site Id Form.

  • Enter both your mailing and site addresses on the manifest. Ensure that the site address is in Block 5.

  • Illegible manifests are treated as discrepancies. Write clearly or type the necessary information on the manifest form.

If 35 days pass from the date on which the waste was initially shipped and you have not received a copy of the manifest from the designated facility, you must contact the transporter and/or the designated facility to determine the whereabouts of the waste. If 45 days pass and the manifest still has not been received, you must submit an exception report to this Department as described below.

Exception Reports

Generators who transport waste off-site must submit an exception report to the Director if they do not receive a copy of the manifest signed and dated by the operator of the designated facility within 45 days from the date on which the waste was initially shipped (Reg 23 § 262.42). The exception report must describe efforts made to locate the waste, and the results of those efforts. Small quantity generators who do not receive a copy of the signed manifest from the designated facility within 60 days must explain the exception on a copy of the original manifest and send it to this Department.

Discrepancy Reports

When a manifest shows a weight difference of more than 10% between the initial weight shown by the generator and the final weight as received by the TSDF, you must attach documentation (a transmittal letter or other memorandum) to your record copy. In many cases such discrepancies are due to the generator estimating the weight of his shipment, and the TSDF actually weighing it upon receipt. If you are unable to resolve the discrepancy with your TSDF, you should forward a copy of the manifest to the ADEQ with an explanation of the discrepancy in Block 18a of the manifest, with an attached letter explaining the discrepancy.