RCRAReadyCompliance 8 min read
Hazardous Waste Manifest Guide: Who Signs and What to Keep (2026)
The hazardous waste manifest travels with each shipment to the disposal facility. This guide explains the form, who signs it, how long to keep it, and what to do if the final signed copy does not come back.
On this page
A hazardous waste manifest is the shipping record that follows hazardous waste from the generator to the facility that treats, stores, or disposes of it. Large and small quantity generators must prepare one for each off-site shipment of hazardous waste, and each handler signs as the waste changes hands.
Most generators do not fill out the manifest themselves, since the waste vendor usually prepares it. The generator’s job after pickup is to confirm that the signed final copy comes back from the disposal facility and to follow up if it does not.
- Your job
Pickup day
Generator
- Prepares the manifest, or your vendor does
- Signs the generator certification
- Keeps a copy
Pickup day
Transporter
- Signs and dates acceptance
- That date starts the 45- and 60-day counts
After delivery
Receiving facility
- Signs for the waste it received
- Gets the final manifest into e-Manifest
- Your job
Follow-up
You
- Look for the signed final copy in e-Manifest
- If it is missing, start the follow-up
Do You Need a Manifest?
- LQGs and SQGs: yes. Hazardous waste you send off site for treatment, storage, or disposal needs one (40 CFR 262.20), with narrow exceptions such as some SQG reclamation contracts. Both must also register with EPA’s e-Manifest system, which is where signed final copies now arrive.
- VSQGs (100 kg or less in a month): generally no. The VSQG exemption takes them out of the federal manifest rules. Going over 100 kg in a month makes the site an SQG, and a VSQG that accumulates 1,000 kg or more of non-acute waste, or more than 1 kg of acute waste, also becomes subject to them. The waste must still go to an authorized facility, and some states and vendors require a manifest regardless.
- Check your category. Generator status is set by each calendar month’s waste. Check yours with the Generator Status Classifier, or see the SQG vs LQG comparison.
The manifest also needs your site’s EPA ID number in Item 1. If you aren’t sure you have one, the EPA ID Lookup searches EPA’s records by name or address.
Reading the Form
The Uniform Hazardous Waste Manifest (EPA Form 8700-22) has 20 numbered items, and a continuation sheet (Form 8700-22A) adds room when a shipment has more waste lines than fit. You or your vendor complete the shipment details before pickup. The transporter and receiving facility complete the rest.
Items 1 through 15 are completed by you or your vendor. Items 16 through 20 are completed by the transporter and receiving facility, or apply to international shipments only.
EPA Form 8700-22
1. Generator ID number
2. Page
3. Emergency response phone
4. Manifest tracking number
5. Generator's name and mailing address
120 Industrial Way, Denver, CO 80202
Phone: (303) 555-0100
6. Transporter 1 company name
U.S. EPA ID number
8. Designated facility name and site address
4500 Reclaim Rd, Commerce City, CO 80022
Phone: (303) 555-0177
U.S. EPA ID number
9a. HM
9b. U.S. DOT description
10. Containers
11. Total quantity
12. Unit
13. Waste codes
14. Special handling instructions and additional information
15. Generator's/offeror's certification
17. Transporter acknowledgment of receipt of materials
18a. Discrepancy indication space
19. Hazardous waste report management method codes
20. Designated facility owner or operator: certification of receipt
| Item | What goes there | Watch for |
|---|---|---|
| 1, 3, 5 | Your EPA ID, emergency response phone, name, mailing address, and phone | Item 3 should reach someone who knows the waste. The Item 5 phone should reach someone who can decide what to do if the facility rejects the load |
| 4 | Manifest tracking number | Preprinted on paper forms and assigned by e-Manifest for electronic ones. Do not create or alter one |
| 9b | DOT description: proper shipping name, hazard class, ID number, packing group | Technical names and reportable quantities where they apply |
| 10–12 | Number and type of containers, total quantity, unit of measure | Report what was shipped, from actual measurements or reasonably accurate estimates. Container capacity is not an acceptable estimate |
| 13 | Up to six waste codes per waste stream | State codes that aren’t redundant with federal codes belong here too |
| 15 | Generator certification | Certifies the shipment is properly described, packaged, marked, and labeled. Generators that aren’t exempt also certify waste minimization |
Source: EPA’s manifest instructions.
Who Signs the Manifest
- You sign the generator certification (Item 15), by hand on paper or with an electronic signature in e-Manifest (262.23(a), 262.24(a)). An employee or agent can sign “on behalf of” the company. If another party prepares the shipment for transport, that party can also sign as the offeror.
- The initial transporter signs and dates acceptance (Item 17). Every follow-up count starts from that date.
- The receiving facility notes any discrepancy (Item 18) and signs for receipt (Item 20). It then gets the final manifest into e-Manifest.
The federal rules do not say who at the generator must sign. A person who certifies a shipment is preparing hazardous materials for transportation, which makes them a hazmat employee under DOT’s rules.
Hazmat employees need training within 90 days of starting the function, and they work under supervision until it is done. The training repeats at least every three years. This is a DOT requirement separate from RCRA, and it applies to a back-up signer such as a shift supervisor or lab manager as well.
Paper, Hybrid, or Electronic
| Paper | Hybrid | Electronic | |
|---|---|---|---|
| Created | On a preprinted form from an EPA-registered printer | In e-Manifest, typically started by the transporter | In e-Manifest by any registered handler |
| Your signature | By hand, with the transporter’s handwritten signature | By hand on a printed copy you keep, with the transporter’s handwritten signature | Electronic |
| Everyone after you | Signs the paper copies | Signs electronically | Signs electronically |
| Final copy | Facility submits it to e-Manifest within 30 days of delivery | Completed in e-Manifest | Completed in e-Manifest |
Since January 22, 2025, receiving facilities no longer have to mail completed manifests back to LQGs and SQGs, and LQGs and SQGs must keep an e-Manifest account to get them. Generators pay nothing to register or use e-Manifest. The receiving facility pays a fee when it submits the final manifest.
A fully electronic manifest needs every handler on it to take part. If only the generator isn’t set up, the hybrid method lets everyone else sign electronically (262.24(c)). Some states, California among them, also want the generator copy of a paper or hybrid manifest. See the California guide.
Following Up: The 45- and 60-Day Rules
A manifest stays open until the receiving facility signs it and the final copy reaches e-Manifest. If you have not received that copy, 40 CFR 262.42 sets the next steps, counted from the date the initial transporter accepted the waste.
LQG Large quantity
SQG Small quantity
VSQG Very small quantity
- 45 LQGs: contact the transporter or facility if the signed copy has not come back.
- 60 LQGs and SQGs: file an exception report in e-Manifest if it is still missing.
- LQGs: at day 45, contact the transporter or receiving facility to find out where the waste is. At day 60, submit an exception report with a legible copy of the manifest and an explanation of what you did to locate the waste.
- SQGs: at day 60, submit a legible copy of the manifest with some indication that you haven’t received confirmation of delivery.
- Both: since December 1, 2025, exception reports go through e-Manifest. EPA no longer accepts mailed paper reports from LQGs and SQGs.
Paper manifests arrive more slowly. The receiving facility has up to 30 days after delivery to submit one, and EPA then needs time to process the image. Check your e-Manifest account and call the facility before you assume a shipment is lost.
When a facility rejects a load and sends it back, you sign the manifest, give the transporter a copy, and send a copy to the facility within 30 days of delivery (262.23(f)).
What to Keep, and for How Long
| Record | Keep for | Source |
|---|---|---|
| Signed manifest | 3 years from the date the initial transporter accepted the waste | 262.40(a) |
| Exception report | 3 years from the report’s due date. An electronic report kept in your e-Manifest account counts | 262.40(b), 262.42(d) |
| Electronic manifest | The signed copy in your e-Manifest account counts, if it’s readily available to an inspector | 262.24(a)(3) |
These periods are extended automatically during an unresolved enforcement action. Manifest follow-up and recordkeeping is one of the six most commonly cited RCRA violations. To see where your own records stand, the Audit Readiness Assessment takes ten questions.
Common Manifest Mistakes
- Counting from the wrong date. The 45- and 60-day counts start on the date the transporter accepted the waste.
- Leaving follow-up to the vendor. EPA says generators must monitor their manifests to verify that shipments are received, even when the vendor prepares them.
- Skipping e-Manifest registration. Final copies are no longer mailed, so an unregistered LQG or SQG may never see one.
- Entering container capacity as the quantity. Item 11 takes the quantity actually shipped.
- Not recording the follow-up. A day-45 call with no written record is hard to prove later.
From Your Containers to the Manifest
In RCRAReady, a pickup is built from the containers you already track, and the manifest follow-up uses the same record.
On your floor
Containers you track
- C-2291
- C-2292
- C-2293
- C-2294
Spent solvent, started Jun 1. Day 71 of 90.
Aug 11
Record the pickup
- Search for or scan the containers going out
- Confirm the pickup date
- The containers close and come off your deadlines
- The 45- and 60-day counts start
Handoff packet
Spent solvent
- Containers
- 4 × DM
- Item 10
- Quantity
- 212 G
- Items 11–12
- Waste codes
- D001 F003 F005
- Item 13
Not the official manifest
- Before pickup: search for or scan the containers going out. Each container carries its waste, codes, and quantity. Before you can record the pickup, RCRAReady checks for gaps such as a missing container type or required waste code.
- For the manifest: the handoff packet lists each line’s container count and type, quantity, and waste codes, plus the generator, transporter, and receiving facility. Your vendor or your staff can copy them onto the manifest. You can view, copy, or print the packet. It is not the official manifest and does not include the DOT shipping description, which comes from you or your vendor.
- At pickup: recording the pickup closes those containers, so they come off your accumulation deadlines, and starts the 45- and 60-day counts from the date the transporter accepted the waste, which is the pickup date you confirm.
Following the Manifest After Pickup
After pickup, RCRAReady tracks each manifest until the final copy is back. An open manifest shows up on screen and in a text message well before day 60.
Example Recycling LLC · 4 containers
Imported from e-Manifest and matched to this pickup
- Picked up
- Aug 11
- Manifest
- 123456789ELC · Electronic
- Category
- LQG
Complete each action outside RCRAReady, then record the date here.
- Record inquiry date
Contact transporter or receiving facility
Due Sep 25
- Record filing date
File exception report
Due Oct 10
Text and email alerts go out before each date.
Regulatory Sources & References
- Official Citation: 40 CFR § 262.20 - Manifest general requirements
- Official Citation: 40 CFR § 262.23 - Use of the manifest
- Official Citation: 40 CFR § 262.24 - Use of the electronic manifest
- Official Citation: 40 CFR § 262.40 - Recordkeeping
- Official Citation: 40 CFR § 262.42 - Exception reporting
- Official Citation: 40 CFR § 262.14 - Very small quantity generators
- Official Citation: 49 CFR § 172.704 - Hazmat employee training
- EPA Guidance: Frequent Questions about e-Manifest
- EPA Guidance: Instructions for completing the Uniform Hazardous Waste Manifest
Frequently asked questions
What is a hazardous waste manifest?
A hazardous waste manifest is the shipping record that travels with hazardous waste from the generator to the facility that treats, stores, or disposes of it. The generator, each transporter, and the receiving facility sign it as custody changes hands, and the receiving facility’s signature confirms delivery. It is EPA Form 8700-22, or an electronic equivalent created in EPA’s e-Manifest system.
Who has to use a hazardous waste manifest?
Large and small quantity generators must prepare a manifest for each off-site shipment of hazardous waste (40 CFR 262.20). Very small quantity generators (100 kg or less in a month) are generally outside the federal manifest rules, but some states and waste vendors still require one.
Can software fill out a hazardous waste manifest for me?
The official manifest is prepared in EPA’s e-Manifest system or on a registered paper form, usually by your waste vendor, and the generator signs it. RCRAReady does not create, sign, or file manifests. It builds each pickup from your tracked containers and produces a handoff packet that lists each line’s container count and type, quantity, and waste codes, which you or your vendor can copy onto the manifest. The DOT shipping description comes from you or your vendor.
Who can sign a hazardous waste manifest?
The generator signs the certification by hand or electronically, and a person can sign on behalf of the company as its employee or agent. When another party prepares the shipment for transport, that party can also sign as the offeror. The person signing is preparing hazardous materials for transportation, so DOT’s hazmat employee training applies: it must be completed within 90 days of starting the function and repeated at least every three years (49 CFR 172.704).
How long must a generator keep hazardous waste manifests?
At least three years from the date the initial transporter accepted the waste (40 CFR 262.40(a)). Exception reports are kept for three years from their due date. The periods are extended automatically during an unresolved enforcement action. For electronic manifests, keeping the signed copy in your e-Manifest account satisfies the rule if it is readily available to an inspector.
What happens if the final signed manifest never comes back?
Count from the date the initial transporter accepted the waste. An LQG that has no signed final copy by day 45 must contact the transporter or receiving facility, and an LQG or SQG that still has none by day 60 must submit an exception report. Since December 1, 2025, exception reports go through EPA’s e-Manifest system rather than by mail (40 CFR 262.42).
What is the difference between paper, hybrid, and electronic manifests?
A paper manifest is a preprinted form from an EPA-registered printer, signed by hand. A hybrid manifest is started electronically in e-Manifest, typically by the transporter, and the generator signs a printed copy by hand, gets the transporter’s handwritten signature on it, and keeps it. An electronic manifest is created and signed in e-Manifest by every handler. The receiving facility submits paper manifests to e-Manifest within 30 days of delivery.
Do generators pay to use e-Manifest?
No. EPA does not charge generators to register, or to create, sign, view, or correct manifests in e-Manifest. Receiving facilities and exporters pay a per-manifest fee when they submit the final signed manifest.
Where do I get a hazardous waste manifest form?
Paper forms come from an EPA-registered printer, because each carries a preprinted manifest tracking number. In practice the waste vendor or transporter usually supplies the form or starts an electronic manifest in e-Manifest.