Variations In Hazardous Waste Generator Reporting

The overview provided in this table is for informational purposes only. Because of the summary nature of the table, it cannot capture all the nuances of the relevant regulations. It is therefore important to consult state, county, or local regulations directly and/or to seek legal advice on particular issues as they may arise. The table addresses only routine periodic reporting and the potential need to submit copies of manifests to regulatory authorities. Other potentially applicable reporting requirements (e.g., spill reporting or "exception reporting" for manifests not received in a timely fashion from the designated treatment, storage, or disposal facility) are not covered. 

Routine Manifest Submission means submission to the state of every hazardous waste manifest for every off-site shipment. In June 2018, the EPA launched the federal e-Manifest system to track hazardous waste shipments electronically, providing generators the option to create and submit manifests electronically. The EPA intends to curtail the use of paper manifests by generators by June 30, 2023. Routine manifest submission is still required in a few states, and these variations are covered by this table. This table does not include requirements related to submission of manifest exception reports which are required in every state. 

The EPA’s 2016 Hazardous Waste Generator Improvements Rule replaced the term CESQG with VSQG in the federal regulations. Many, but not all, states now use this category. The 2016 Rule also includes a requirement for all SQGs to re-notify the EPA of their hazardous waste activities every four years. The first re-notification is due by September 1, 2021. The re-notification requirement is effective in authorized states that have adopted the Hazardous Waste Generator Improvements Rule. Not all authorized states have adopted the Hazardous Waste Generator Improvements Rule yet, however. 

The overview provided in this table is for informational purposes only. Because of the summary nature of the table, it cannot capture all the nuances of the relevant regulations. It is therefore important to consult the regulations directly and/or to seek legal advice on particular issues as they may arise.