The Hazardous Waste Manifest System is a set of forms, reports, and procedures designed to seamlessly track hazardous waste from the time it leaves the generator facility where it was produced, until it reaches the off-site waste management facility that will store, treat, or dispose of the hazardous waste. The system allows the waste generator to verify that its waste has been properly delivered, and that no waste has been lost or unaccounted for in the process.
The key component of this system is the Uniform Hazardous Waste Manifest which is a form prepared by all generators who transport, or offer for transport, hazardous waste for off-site treatment, recycling, storage, or disposal. Currently, the manifest is a paper document containing multiple copies of a single form. When completed, it contains information on the type and quantity of the waste being transported, instructions for handling the waste, and signature lines for all parties involved in the disposal process. The manifest is required by DNR, EPA and Department of Transportation. Each party that handles the waste signs the manifest and retains a copy for themselves. This ensures critical accountability in the transportation and disposal processes. Once the waste reaches its destination, the receiving facility returns a signed copy of the manifest to the generator, confirming that the waste has been received by the designated facility.
Staff who sign Uniform Hazardous Waste Manifests must be hazmat employees in accordance with 49 CFR 172 Subpart H. See hazardous materials transportation, or .
General regulatory citations
NR 662 Subchapter B
NR 662.042 Exception reporting (LQG)
NR 662.191 Conditional manifest exemption (SQG)
NR 662.193 (2) Exception reporting (SQG)
NR 662.220 (5)(f) (VSQG – acute HW)
NR 662.220 (5)(g) (VSQG – non- acute HW)
Routing for manifests from UW System generators:
- For hazardous waste sent to Veolia’s Menomonee 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 or PCB waste sent to Illinois: The generator must submit a copy (photocopy) within two days to Illinois EPA, Division of Land Pollution Control, P.O. Box 19276, Springfield, IL 62794-9276
- For hazardous waste sent to out-of-state TSDFs: The only copies that you will be required to send to Wisconsin DNR will be for out of state shipments (for UW , 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.
- Non-RCRA waste: WDNR does not want you to mail them manifest copies for non-RCRA waste; that is, waste without a hazardous waste code in column 13. 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.
Veolia field teams can provide mailing envelopes and instruction. Regulatory requirements are to retain manifests for three years. UW System Administration asks campuses to keep manifest copies in perpetuity, due to disposal liability concerns.
Training Powerpoint, quiz Word document and quiz key are available from ORM for University of Wisconsin staff
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.