What the Heck Do I Do With A Manifest?

Our California clients, especially new Safety or Environmental Services Managers, often ask us for guidance on understanding manifests, why they are important and what they need to do with them to be in full compliance.  (If you operate in other states, this post is still informative but the laws in your state may be a little different.  Make sure to check your state’s requirements so you stay in compliance.)  California, this post is for you!  Let’s get into it.

Question 1: What is a manifest?

A manifest is the shipping document that accompanies hazardous waste when it leaves your facility.  It is the document that keeps track of the waste as it moves from generation (when your organization collects, stores and schedules for pick up from your facility) through transportation, storage, and finally ending at the TSDF (Treatment, Storage, and Disposal Facility).  This document collects information as the waste moves through the process and allows you to prove the “cradle-to-grave” handling of the waste.  This is especially important since your organization is responsible for the waste from the time it is collected (cradle), to the time it is permanently disposed of (grave).  See the regulation here. 

The manifest is a chain of custody and requires each company handling the waste to record the dates they handled it and for the TSDF, how it was disposed of.  

Question 2: My waste hauler (transporter) just gave me the manifest to sign; do I just sign it?  

NOOOOO!  Before you can sign a manifest, make sure you have been trained and have your certificate of training (in case you need to prove it).  (For more information on training requirements, see the blog post called Manifest Training: What is Required?) Only after you have been trained can you sign; but wait!  Check to make sure the information on the manifest is correct.  By double checking with your waste hauler to see that the quantities and types of waste picked up are correct and that the waste codes are correct, you may save yourself some time and headaches when mistakes are caught later.  

Ask your waste hauler if everything on the manifest is correct; go through it line by line until you are very familiar with the manifest, your waste hauler’s processes, and the types of waste your organization generates.  Once you have confirmation that everything is correct, only then can you sign it.  

Question 3: After I sign it, I usually just put it in a binder. Is that all I need to do?  

Again, nooooooo!  After you sign the manifest (and you will learn this in your training), make a copy.  Place the original, along with any other documentation, work order, landfill disposal document, etc. in a binder.  These original manifests will be used to calculate how much waste your facility generates in a year and the inspectors WILL look at these for accuracy.  They will also be used to match up with the final copy (signed by generator, transporter and TSDF).  Once you have both copies, the original and the final, signed copy, the cradle-to-grave process is complete.  

Now, back to the copy you made.  Best practice is to wait about a week before mailing it to the DTSC (Department of Toxic Substances Control).  Yes, you need to mail all the initial generator copies to the State of California within 30 days of the waste leaving your facility.  This copy shows that you have, in good faith, sent your waste with a certified waste hauler and know that it is your responsibility to keep track of it until you get the final copy back alerting you that the waste has reached its final destination.  Here is the mailing address for sending the manifests:

DTSC Generator Manifests

P.O. Box 400

Sacramento, CA 95812-0400

Pro Tip: It is also best practice to create mailing labels, so you don’t have to write this out each time you mail a manifest.  

Question 4: How long do I need to keep the manifests?  

All manifests must be kept for 3 years from the first date the transporter (waste hauler) signed the manifest (or longer if there is any pending action against your organization).  Your organization may have a more stringent policy on recordkeeping, in general, so make sure to check before you shred the documents.  Depending on whether you are a small quantity generator (SQG) or a large quantity generator (LQG), there may be other recordkeeping requirements as well.  See info here.  

Question 5: What should I do if I don’t get the copy back from the TSDF? 

From to the DTSC website, “If you don’t receive the Signed Copy Returned by the facility within 35 days, you have to contact the transporter and the facility to at-tempt to locate the shipment.”  Hopefully, if this happens, your waste hauler will help.  Usually, they keep copies and can get them easily.  

You must send a manifest exception report to DTSC if you still have not located the shipment within these time frames:

• 45 days for large quantity generators (more than 1,000 kilograms per month or 6,000 kilograms on site at any one time).
• 60 days for smaller generators and 90 days if the transportation was by water or the waste was exported.

Question 6: What do I do if there is a mistake on the manifest? 

Hopefully you can catch errors prior to the waste leaving your facility.  If this is the case, strike through, with one line, the mistake, and correct it making sure to initial the information you changed.  If it was an error by your waste hauler, ask them to strike through the information and initial the change.  

If the error was caught after the waste left your facility, you will need to send a manifest correction letter to the DTSC stating that there was an error and state what it was.  If, for example, a waste code was wrongly assigned and the error wasn’t caught for weeks or months, and occurred on several manifests, you can list in your letter what the error was, and all the manifest numbers it affected.  Note: The state doesn’t punish you for self-reporting if you report before they find the errors!  So, keep your eyes open and stay curious.  

If you want more technical information on manifests, look here.  For questions or assistance, please email kt@trapanegroup.com