A hazardous waste manifest is the tracking document that travels with a shipment of hazardous waste from the site that generated it, through each transporter, to the facility that will treat, store, recycle or dispose of it. In the United States the manifest is EPA Form 8700-22, the Uniform Hazardous Waste Manifest, which can be completed on paper or electronically through EPA's e-Manifest system.
The manifest matters because it creates a "cradle-to-grave" record. Under RCRA, the generator remains responsible for its waste even after it leaves the site, and the manifest is the main evidence that the waste reached the right place.
What Is a Hazardous Waste Manifest?
The manifest requirements are in 40 CFR Part 262, Subpart B. Small quantity generators (SQGs) and large quantity generators (LQGs) must use a manifest for every off-site shipment of hazardous waste. Very small quantity generators are generally not required to use a manifest under federal rules, although some states require one. If a shipment needs more lines than the main form allows, the continuation sheet, Form 8700-22A, is used.
The manifest records:
- The generator's name, site address, mailing address and EPA identification number.
- Each transporter's name and EPA ID number.
- The designated facility's name, address and EPA ID number.
- A U.S. DOT description of each waste, the number and type of containers, the quantity and the waste codes.
- Emergency response information and a 24-hour emergency phone number.
- The generator's certification and signature, and signatures from each transporter and the receiving facility.
Because the manifest includes the DOT shipping description, it is also used as the shipping paper under the hazardous materials transportation rules, so the person preparing it needs the right DOT hazmat training.
Paper Manifests and e-Manifest
EPA launched its national e-Manifest system in 2018. Manifests can be fully electronic, a hybrid in which the generator signs on paper and later parties sign electronically, or paper. In all cases the receiving facility submits the final manifest to e-Manifest, which pays for the system through user fees charged to receiving facilities.
EPA's most recent e-Manifest rule made several changes for generators:
- Registration: since January 22, 2025, SQGs and LQGs must have at least one person registered in EPA's RCRAInfo system with Site Manager or Certifier access.
- Final copies: receiving facilities submit the final signed manifest to e-Manifest, and generators are expected to retrieve and review it there rather than rely on a mailed copy.
- Corrections: generators must correct their portion of a manifest when EPA or a state asks for a correction.
- Exception reports: since December 1, 2025, exception reports are submitted electronically in e-Manifest.
The Return Copy and Exception Reports
Once the waste reaches the designated facility, the facility signs the manifest to confirm receipt and notes any discrepancies. The generator must confirm that the final signed manifest has been received, now usually by checking e-Manifest. If it is not received, the generator must follow up:
- LQGs: if the generator has not received the final signed manifest within 45 days of the date the initial transporter accepted the waste, it must contact the transporter and facility to find out what happened. If it still has not received it within 60 days, it must submit an exception report describing the search and its results.
- SQGs: if the final signed manifest has not been received within 60 days, the SQG submits a copy of the manifest with a note that confirmation of delivery was not received.
These timeframes were updated by EPA's recent e-Manifest rule. State programs adopt federal changes on their own schedules, so confirm the timeframes that apply in your state.
Recordkeeping: The 3-Year Rule
Generators must keep a copy of each manifest for at least three years from the date the waste was accepted by the initial transporter, and keep exception reports for at least three years as well. The retention period is automatically extended during any unresolved enforcement action. Manifests in e-Manifest can be accessed there, but many generators also keep copies in their own files for audits.
How to Complete a Hazardous Waste Manifest Step by Step
- Confirm your status and IDs. Make sure your site has an EPA ID number and that your transporters and designated facility have theirs.
- Characterize the waste. Identify the waste codes and the correct DOT shipping description for each waste stream.
- Prepare the containers. Package, mark and label containers to DOT and EPA requirements before the transporter arrives.
- Complete the generator sections. Fill in or review the generator information, waste descriptions, container counts and quantities, often with help from the waste vendor.
- Sign the certification. A trained, authorized person signs the generator certification and dates it, on paper or electronically.
- Get the transporter's signature. The transporter signs and dates the manifest when it takes the waste, and the generator keeps its copy.
- Track delivery. Check e-Manifest for the final signed manifest and review it for discrepancies.
- Follow up on missing manifests. Contact the transporter and facility and file exception reports on time if confirmation does not arrive.
- Keep the records. Retain manifests and exception reports for at least three years.
Common Mistakes to Avoid
- Signing a manifest prepared by a vendor without checking the waste codes, quantities and descriptions.
- Letting someone without DOT hazmat training sign the generator certification.
- Not having an active RCRAInfo user for the site, which makes it hard to view final manifests and submit exception reports.
- Waiting for a mailed copy instead of checking e-Manifest.
- Missing exception report deadlines.
- Losing manifest records before the three-year retention period ends.
How SMS360 Helps
SMS360's Document Library gives teams a central place to store manifests, exception reports and waste profiles so records are easy to find during audits. Compliance Management can track follow-up dates for missing manifests, and Training Management keeps records of the DOT hazmat and RCRA training for people who sign manifests.
Frequently Asked Questions
Do very small quantity generators need a manifest?
Not under federal rules, but some states require VSQGs to use a manifest or other shipping documents. Check your state's rules. See our page on RCRA hazardous waste generator requirements for more on generator categories.
How long must I keep hazardous waste manifests?
At least three years from the date the waste was accepted by the initial transporter. The period is extended automatically during any unresolved enforcement action.
What is an exception report?
An exception report tells the regulator that a generator has not received confirmation that its waste reached the designated facility. LQGs and SQGs have different timeframes and content requirements, and reports are now submitted through e-Manifest.
Is the manifest also the DOT shipping paper?
The manifest contains the DOT shipping description and emergency information, and it is commonly used as the shipping paper for hazardous waste shipments, so it must meet DOT shipping paper requirements as well as EPA's.
