Compliance
Manifests and recordkeeping
The paperwork that survives an inspection, and what has to be in it.
Every hazardous waste shipment travels on the Uniform Hazardous Waste Manifest, EPA Form 8700-22. The generator completes and signs it, each transporter signs, the receiving facility signs on arrival, and a signed copy returns to the generator. Records are kept at least three years.
Source: 40 CFR Part 262, Subpart BThe document set
A compliant shipment produces more than a manifest:
- Uniform Hazardous Waste Manifest, EPA Form 8700-22, with all applicable waste codes
- Land disposal restriction notification for every regulated stream
- DOT shipping papers and emergency response information
- Waste profile with the determination and its supporting basis
- Certificate of destruction or treatment from the receiving facility
- Exception report where a signed copy does not return in time
The manifest proves the waste left. The certificate proves what happened to it. Generators frequently hold the first and not the second, and it is the second that answers the question an inspector actually asks.
Why this is the product
Anyone with a truck and a permit can move a drum. What a generator is actually buying is an accurate description, correct codes, a receiving facility permitted for those codes, and a record that closes properly.
Cradle to grave liability makes that record the only durable protection a generator has. Years after a drum has gone, the file is what demonstrates the waste was characterized correctly and sent somewhere authorized to take it.
Common questions
How long must manifests be kept?
At least three years from the date the transporter accepted the waste, under 40 CFR 262.40. The period extends automatically during an enforcement action. Many generators keep them permanently, because the liability outlasts the retention requirement.
Who is responsible for accuracy?
The generator. Signing the manifest certifies that the description is accurate and the contents properly classified, packaged, marked and labeled. A transporter or broker may help, but the certification is the generator's.
What if I find an error after shipment?
Contact the receiving facility and the transporter immediately. Corrections are handled through the e-Manifest system. An uncorrected error that surfaces later looks materially worse than one that was caught and fixed.
Related services
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This page summarizes federal requirements and is not legal advice. State programs can be more stringent than the federal baseline. Verify against current federal and state regulations before acting. Last reviewed September 2026.