The Wisconsin Department of Natural Resources inspectors say some chemical hazardous waste generators aren’t submitting a Uniform Hazardous Waste Manifest for their chemical waste. We’ll try to help by clarifying exactly what these manifests are. We’ll also explain who needs to submit them and when.
Uniform Hazardous Waste Manifest
According to the DNR, “The Uniform Hazardous Waste Manifest is a form prepared by generators of hazardous waste who transport hazardous waste for off-site treatment, recycling, storage or disposal. This ensures critical accountability in both the transportation and disposal processes. ”
Multiple agencies require this manifest. They include the U.S. Department of Transportation, the U.S. Environmental Protection Agency and the Wisconsin DNR. By submitting this manifest, these agencies and the waste producer can verify the waste was properly delivered. More importantly, that no waste was lost or unaccounted for during the process.
Yet, either because of negligence, lack of education, or pure indifference, some hazardous waste generators aren’t properly submitting them. If at all. Not only can this be hazardous for public and environmental safety, but violators can also receive heavy fines for failing to submit their manifests.
No more excuses. Here’s what you need to know about submitting a hazardous waste manifest.
Who Needs to Submit the Hazardous Waste Manifest?
Before 2006, all generators had to send the DNR all hazardous waste manifests themselves. However, the rules have since changed. Here’s a breakdown of the rules as of today according to the DNR:
- Generators do not need to send manifests to the DNR if they send their waste to a hazardous waste management facility within Wisconsin. In this case, the facility is responsible for sending the manifest to the DNR.
- Generators do need to to send a final, signed manifest copy to the DNR when sending hazardous waste to a facility that is outside of the state. In this case, you must submit a copy of each manifest to the DNR within 30 days of receiving it from the designated Treatment, Storage or Disposal (TSD) facility.
- Some small quantity generators (who generate between 220 and 2205 pounds of hazardous waste per month) may be exempt from using the manifest system if their waste is reclaimed under a contractual agreement and meets certain conditions (see NR 662.191, Wis. Adm. Code for more information).
- Very small quantity generators (less than 220 pounds of hazardous waste per month) do not have to use a hazardous waste manifest system.
How Long You Need to Keep Your Hazardous Waste Manifest
Please note that even if you do not need to submit a manifest, you still must complete one. As a waste generator, you are responsible for completing your respective sections of the manifest before shipping. Then, transporters and the TSD facility must complete various parts of the manifest before sending a copy back to you.
Once you receive the manifest copy from the TSD, you must retain it for at least three years. You are responsible for retaining copies regardless of whether your waste is sent to an in-state or out-of-state facility.
Hazardous waste generators who need to mail manifest copies can send them to this address:
Department of Natural Resources
Bureau of Waste and Materials Management
PO Box 8094
Madison WI 53708
We hope this overview gives you a better understanding of why these hazardous waste manifests are important and who needs to submit them to the DNR. Remember, the manifests aren’t just about meeting regulations and avoiding fines. They’re about keeping the public and your environment safe.