What does 49 CFR 172.205 (Hazardous waste manifest) require?

Short answer

49 CFR 172.205 requires a hazardous waste manifest, specifically an EPA Form 8700-22 and 8700-22A, to be prepared and signed by the shipper and initial carrier, and carried during transportation. The manifest must be dated and bear the handwritten signature of the person representing the shipper, initial carrier, and subsequent carriers, as well as the designated facility receiving the waste.

The rule says

"No person may offer, transport, transfer, or deliver a hazardous waste (waste) unless an EPA Form 8700-22 and 8700-22A (when necessary) hazardous waste manifest (manifest) is prepared in accordance with 40 CFR 262.20 and is signed, carried, and given as required of that person by this section." (49 CFR 172.205(a))

"The original copy of the manifest must be dated by, and bear the handwritten signature of, the person representing: (1) The shipper (generator) of the waste at the time it is offered for transportation, and (2) The initial carrier accepting the waste for transportation." (49 CFR 172.205(c))

"A copy of the manifest must be dated by, and bear the handwritten signature of the person representing: (1) Each subsequent carrier accepting the waste for transportation, at the time of acceptance, and (2) The designated facility receiving the waste, upon receipt." (49 CFR 172.205(d))

In plain English

It requires the shipper, initial carrier, and subsequent carriers to sign and date the manifest, and for the designated facility to sign and date the manifest upon receipt. The manifest must be carried during transportation and retained by the shipper, initial carrier, and subsequent carriers for three years. This ensures that the waste is properly identified, handled, and disposed of, and provides a paper trail in case of an incident or inspection.

What to do

• Prepare the hazardous waste manifest on EPA Form 8700-22 and 8700-22A, as required by 40 CFR 262.20.
• Sign and date the manifest as the shipper, initial carrier, or subsequent carrier, as required by 49 CFR 172.205(c) and (d).
• Carry the manifest during transportation, as required by 49 CFR 172.205(e).
• Retain a copy of the manifest for three years, as required by 49 CFR 172.205(e).