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406 Waste Management Practices: Municipal, Hazardous, and Industrial
The SQG must ensure that all employees are familiar with the proper waste handling and emer-
gency procedures relevant to their responsibilities during facility operations and emergencies. No
paper plan is required for the SQG (U.S. EPA, 2001b)

12.4.9 REPORTING
The LQG is responsible for submitting a biennial report to the state regulatory agency. Reports sub-
mitted for off-site shipping must include the facility’s EPA identification number, information
regarding the transporter and permitted TSDF, a description and quantity of the wastes generated,
and actions taken to reduce the volume and toxicity of the waste. These reports can be used to
encourage waste reduction (pollution prevention) within the facility. Some states require the LQG
to report annually to the regulatory agency.

12.4.10 SHIPMENT OF WASTES OFF-SITE
The generator must package, label, and mark all waste containers and placard vehicles that carry
the wastes according to Department of Transportation requirements (49 CFR Parts 172, 173, 178,
and 179) (see Chapter 13). Additionally, a Uniform Hazardous Waste Manifest must accompany all
hazardous waste shipped off-site.

12.4.11 THE UNIFORM HAZARDOUS WASTE MANIFEST
The Uniform Hazardous Waste Manifest is a paper form initiated by any generator that removes
hazardous waste off-site for treatment, recycling, storage, or disposal. Both DOT (see Chapter
13) and EPA require the manifest. Each party that handles the waste, including the generator, all
transporters, and TSDFs, signs the manifest and retains a copy. Once the waste reaches its final
destination the TSDF returns a signed copy of the manifest to the generator. This cycle of signa-
tures and paperwork confirms that the waste has been received and the loop is closed. Several
states require the TSDF to forward a copy of the completed manifest to the state regulatory
agency as well. When completed, the manifest contains information on the type and quantity of
the waste that was transported, instructions for handling the waste, and signatures of all parties
involved in the management process (Figure 12.4). CESQGs are not required to use a manifest
when shipping wastes off-site. Detailed instructions for completing the manifest are given in
Table 12.5.
If the LQG facility does not receive a signed manifest from the TSDF after 35 days (60 days
for SQGs), it must attempt to locate the hazardous waste by contacting the TSDF. If there is no
response after 45 days the LQG must submit an Exception Report to the state regulatory agency.
The exception report (40 CFR Part 262.42) notifies the agency of a potential problem in the
cradle-to-grave tracking process. The exception report contains a copy of the original manifest
and a cover letter describing efforts made to locate the shipment. A flow chart for the manifest
paper trail is shown in Figure 12.5. A completed albeit questionable uniform hazardous waste
manifest is shown in Figure 12.6.
The manifest requirements outlined above apply only to domestic shipments of hazardous waste
by road. Domestic shipments by rail or water are subject to other manifest requirements. Hazardous
wastes exported from the United States are subject to additional regulatory requirements (40 CFR
Part 261, 262).

12.4.12 RECORD KEEPING
The LQG must retain the following records at the facility for at least 3 years: signed manifests, bien-
nial and exception reports, test results, and waste analyses. The 3-year-period is automatically
extended in the event of an on-going enforcement action (40 CFR 262.40).