RCRAReadyHazardous 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...
RCRA Readiness Check
Answer 10 questions to find gaps in your hazardous waste practices. Takes about three minutes.
Question 1 of 10 0%
Accumulation
Are your CAA containers correctly dated and within their accumulation limits?
Mark each central accumulation area (CAA) container with its start date and manage the waste within its time limit.
40 CFR 262.16(b)(6) and 262.17(a)(5)
Accumulation
When satellite waste exceeds its limit, do you date and manage the excess within three calendar days?
Date the containers holding excess waste and complete a permitted management action within three consecutive calendar days.
Limits and required actions
The limits are 55 gallons of non-acute hazardous waste, one quart of liquid acute hazardous waste, or 1 kg of solid acute hazardous waste at the point of generation. The trigger is exceeding a limit, not filling a container. Within three consecutive calendar days, comply with CAA standards or remove the excess to a compliant CAA, an on-site permitted/interim-status TSDF, or an off-site designated facility.
Accumulation
Could someone cover waste deadlines while you’re away?
A backup should be able to access current records and arrange timely waste management. This is a recommended safeguard.
40 CFR 262.16(b)–(e) and 262.17(a)–(b)
Manifests & Reporting
Do you follow up on missing signed manifests on time?
For domestic shipments, LQGs must inquire at 45 days if the final signed manifest is missing. SQGs and LQGs must file an Exception Report at 60 days if it is still missing. Count from the initial transporter’s acceptance date.
EPA e-Manifest frequently asked questions
Manifests & Reporting
Do you have a process for filing required Exception Reports?
Assign responsibility for filing on time, even when a vendor causes the delay. You can answer yes if your process is ready but no report has been needed.
EPA exception reporting guidance
Manifests & Reporting
Can your team submit Exception Reports through e-Manifest?
Your site needs an account with Site Manager or e-Manifest Certifier permissions and someone responsible for filing. SQG and LQG Exception Reports must be submitted electronically.
EPA e-Manifest registration requirements
Records & Inspections
Are your required waste records complete and available?
Keep required manifests, reports, and waste determination records for their retention periods. They should be available for inspection.
Records & Inspections
Do you inspect CAA containers weekly and address problems?
Inspect at least weekly for leaks and deterioration, and take required corrective action. Check state rules for inspection-log requirements.
40 CFR 262.16(b)(2)(iv) and 262.17(a)(1)(v)
Records & Inspections
Can you control and trace changes to your records?
Limit who can change records and keep corrections traceable. These recommended safeguards help preserve accurate records.
Waste Determination
Have you documented whether each waste stream is hazardous?
Assess waste before dilution or mixing, using adequate process knowledge and/or appropriate testing. Keep support for hazardous and nonhazardous conclusions, identify applicable waste codes, and reassess when properties may change the classification.
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Analyzing...
Score by topic
Accumulation
0 / 9
Manifests & Reporting
0 / 9
Records & Inspections
0 / 9
Waste Determination
0 / 3
What to review
This check covers selected federal SQG/LQG practices, not every requirement. Verify your answers and review state rules before drawing compliance conclusions.
Keep these practices on track
RCRAReady tracks accumulation deadlines, manifest follow-up, weekly inspections, and audit trails. 30 days free, then $150 per facility per month.
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Frequently asked questions
About this check and the requirements behind it.
Who is this check for?
This tool screens selected federal requirements for small and large quantity generators (SQGs/LQGs). Confirm your generator category and state requirements. It is not a VSQG assessment or a complete compliance audit; training, emergency planning, container management, tanks, special waste rules, and exports may need separate review. Sources reviewed September 16, 2026.
How are answers scored?
Paper and digital processes receive equal credit; immutable logs are not required by general federal generator recordkeeping rules. Choose “Unsure” if applicability is uncertain. Not-applicable answers are excluded from the score, and missing or uncertain practices are flagged for review, regardless of your total score.
What triggers an EPA RCRA inspection?
Inspections may be routine or prompted by complaints, reported incidents, compliance information, or enforcement priorities. This check does not predict whether your facility will be inspected or what an inspector will find.
Which requirements should a hazardous waste review cover?
Review waste determinations, generator category, container condition and closure, labels and dates, accumulation limits, manifests, inspections, personnel training, emergency preparedness, and applicable reporting. This tool covers only selected practices and does not rank violations by frequency.
What happens if I miss the manifest follow-up window?
For LQGs, a missing final signed manifest copy triggers an inquiry duty at 45 days. If the signed copy is still missing at 60 days, both LQGs and SQGs must submit an Exception Report. Beginning December 1, 2025, SQG and LQG Exception Reports must be submitted electronically through e-Manifest rather than mailed on paper.
What is a generator status reclassification and why does it matter?
Generator category is determined month by month under 40 CFR 262.13. If you exceed a monthly threshold — for example, moving from SQG to LQG — the stricter category generally applies to waste generated that month unless a qualifying episodic generation provision applies. Common consequences include a drop from 180-day to 90-day accumulation limits, additional training requirements, and mandatory contingency planning.
How often must I conduct on-site hazardous waste inspections?
Both SQGs (40 CFR 262.16(b)(2)(iv)) and LQGs (40 CFR 262.17(a)(1)(v)) are required to inspect Central Accumulation Area containers at least weekly for leaks and container deterioration. Tank systems have additional operating-day and weekly inspection requirements. The federal CAA container rules do not create a universal written-log requirement, but a dated inspection log can help demonstrate that inspections occurred, and state programs may require one.
How long must I keep hazardous waste records?
Under 40 CFR 262.40, signed manifest copies must generally be retained for at least three years from the date the waste was accepted by the initial transporter. Biennial Reports and Exception Reports must be kept for at least three years from the due date of the report. SQG/LQG hazardous waste determination records have their own three-year retention period under 40 CFR 262.11(f), measured from the date the waste was last sent for treatment, storage, or disposal. Retention periods are extended during unresolved enforcement actions or when EPA requests it.
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