Requirement for Waste Generators, Transporters, and Management Facilities under the RCRA Hazardous Waste Manifest System Renewal

The US Environmental Protection Agency (EPA) is planning to submit an Information Collection Request (ICR), to the Office of Management & Budget (OMB) related to the Resource Conservation and Recovery Act (RCRA).

In the May 13th Federal Register (FR) Vol. 89, No. 93, the EPA announced it’s plan to submit an ICR to OMB for the Requirements for Generators, Transporters, and Waste Management Facilities under the RCRA Hazardous Waste Manifest System to the OMB for review and approval.

Generators, transporters, and TSDFs handling hazardous waste are currently required to complete the data requirements for manifests and other reports primarily to:

  1. Track each shipment of hazardous waste from the generator to a designated facility;
  2. Provide information requirements sufficient to allow the use of a manifest in lieu of a Department of Transportation shipping paper or bill of lading;
  3. Provide information to transporters and waste management facility workers on the hazardous nature of the waste;
  4. Inform emergency response teams of the waste’s hazard in the event of an accident, spill, or leak; and
  5. Ensure that shipments of hazardous waste are managed properly and delivered to their designated facilities.

The EPA is now soliciting public comments on the following specific aspects on data requirements for hazardous waste manifests to enable it to:

  • Evaluate whether the proposed collection of information is necessary for the proper performance of the functions of the Agency, including whether the information will have practical utility;
  • Evaluate the accuracy of the Agency’s estimate of the burden of the proposed collection of information, including the validity of the methodology and assumptions used;
  • Enhance the quality, utility, and clarity of the information to be collected;
  • Minimize the burden of the collection of information on those who are to respond, including through the use of appropriate forms of information technology.

EPA will consider the comments received and amend the ICR as appropriate. This ICR may have major impact on current recordkeeping and reporting activities related to the current hazardous waste manifest paper and electronic system.

Please feel free to contact Conversion Technology Inc. (CTI) at if you have any questions about your potential requirements as a waste generator or management facility or if you want to discuss how to be in compliance with the regulations.

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