Safety & Loss Prevention

Manifests: new federal HW manifest

Q: What about the new federal manifest that will be replacing the Wisconsin manifest as of September 2006? What procedures need to be followed by campuses for future shipments with the new manifest?

A: A summary of the main changes to the manifest requirements that will be effective on September 5, 2006, is provided below. These requirements apply to all facilites using the manifest. All UW System facilities use the manifest for hazardous waste shipments, so this applies to all facilities and generator categories.

 

  • For hazardous waste sent to Veolia's Menonomee Falls facility (or any other Wisconsin TSDF): Generators are no longer required to send initial copies of manifests, or any manifests, to the department if the waste is sent to a Wisconsin hazardous waste management facility for treatment, storage or disposal.
  • For hazardous waste sent to out-of-state TSDF's: * The only copies that you will be required to send to Wisconsin DNR will be for out of state shipments (for us, usually to incinerators in Illinois or Texas ). When you receive the signed copy from the disposal facility, you will need to make a copy and send it to the DNR. You will have 30 days. [NR 662.023(3)]. Copies can be sent to the Department of Natural Resources, Bureau of Waste and Materials Management, Box 8094, Madison, WI 53708.
  • Waste codes: There are no longer any Wisconsin specific hazardous waste codes (e.g.F500).

 

Click here for a view of the new uniform manifest with comments on the new fields (courtesy Veolia ES Technical Solutions, L.L.C.)

 

Manifests: Wisconsin HW Manifest Checklist

Q: Is there a checklist available to UW campuses to assist in double-checking the Wisconsin hazardous waste manifest prior to signing it?

A: Yes, there is a checklist. Click here for a copy. Requires Adobe Acrobat Reader.

 

Manifests: Texas Manifest Copies

Q: Do UW campuses need to send a copy of the Texas manifest to the Wisconsin Department of Natural Resources (WDNR)?

A: Under the structure of our current hazardous waste management contract, your campus hazardous waste program may occasionally need to use the Texas waste manifest. This occurs because our only approved disposal facility for polychlorinated biphenyl (PCB) wastes is in Port Arthur, Texas .

If your manifest is for non-RCRA PCB wastes, do not send them a copy. According to the WDNR, in a letter to one of our campuses:

“Section NR 157.03(2) requires persons generating PCBs to document disposal using a waste tracking form (a hazardous waste manifest form) provided by the WDNR. The generator is required to maintain records of all waste tracking forms (hazardous waste manifests) for inspection by the WDNR. However, the tracking forms for PCBs do not need to be routed to WDNR.”

WDNR does not want you to mail them manifest copies for non-RCRA PCB's.

If your waste is being manifested to Texas because it is both RCRA hazardous (it will have a RCRA waste code in column I of the manifest) and PCB contaminated, then it is considered hazardous waste and copies are sent to WDNR in the same manner as other out-of-state manifests.

 

Manifests: PCB Manifest Copies

Q: Should my campus send a copy of a manifest that has TSCA wastes (PCBs) but no RCRA hazardous wastes to the Wisconsin Department of Natural Resources (WDNR)?

 A: No. If your manifest is for non-RCRA PCB wastes only, do not send the WDNR a copy. According to the WDNR, in a letter to one of our campuses:

“Section NR 157.03(2) requires persons generating PCBs to document disposal using a waste tracking form (a hazardous waste manifest form) provided by the WDNR. The generator is required to maintain records of all waste tracking forms (hazardous waste manifests) for inspection by the WDNR. However, the tracking forms for PCBs do not need to be routed to WDNR.”

WDNR does not want you to mail them manifest copies for non-RCRA PCB's.

[Note: If your waste is both RCRA hazardous and PCB contaminated, then it is considered hazardous waste and copies are sent to WDNR in the same manner as other RCRA hazardous waste manifests. RCRA hazardous waste will have a RCRA waste code in the Waste Codes section of the manifest.]

 

 

 

 

 

Updated October 18, 2007

This publication was prepared for environmental, health and safety staff at University of Wisconsin System campuses, to assist in finding resources and information for regulatory compliance. It is not intended to render legal advice. (Click here to read full legal disclaimer.)