Supporting Statement For 

Information Collection Request (ICR) Number 801.20 

Requirements for Generators, Transporters, and Waste 

Management Facilities under the RCRA Hazardous 

Waste Manifest System 

 April 30, 2015 
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TABLE OF CONTENTS

1. IDENTIFICATION OF THE INFORMATION COLLECTION ....................................... 1

1A. Title and Number of the Information Collection .................................................... 1

1B. Short Characterization ............................................................................................ 1

2. NEED, AUTHORITY & USE FOR THE INFORMATION ............................................. 2

2A. Need & Authority to Collect Information ............................................................... 2

2B. Practical Utility & Users of the Information ........................................................... 2

3. NONDUPLICATION, CONSULTATIONS & OTHER COLLECTION CRITERIA ...... 3

3A. Nonduplication ........................................................................................................ 3

3B. Public Notice ........................................................................................................... 4

3C. Consultations........................................................................................................... 4

3D. Effects of Less Frequent Collection ........................................................................ 5

3E. Confidentiality ........................................................................................................ 6

3F. Sensitive Questions ................................................................................................. 6

4. THE RESPONDENTS AND THE INFORMATION COLLECTED ................................ 6

4A. Respondent Standard Industrial Classification Codes ............................................ 6

4B. Information Requested ............................................................................................ 6

5. AGENCY ACTIVITIES, COLLECTION METHODOLOGY & INFORMATION 

MANAGEMENT .............................................................................................................. 27

5A. Agency Activities .................................................................................................. 28

5B. Collection Methodology & Management ............................................................. 28

5C. Small Entity Flexibility ......................................................................................... 28

5D. Collection Schedule .............................................................................................. 29

6. ESTIMATE OF BURDEN HOURS & COST ................................................................. 30

6A. Estimating the Respondent Universe .................................................................... 30

6B. Estimating Respondent Costs ............................................................................... 33

6C. Estimating Agency Hour and Cost Burden ........................................................... 35

6D. Estimating Respondent Hours and Costs .............................................................. 36

6E. Bottom Line Burden Hours & Cost ...................................................................... 54

6F. Reasons for Change in Burden ............................................................................. 59

6G. Burden Statement .................................................................................................. 60
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1. IDENTIFICATION OF THE INFORMATION COLLECTION 

1A. Title and Number of the Information Collection 

This ICR is entitled, “Requirements for Generators, Transporters, and Waste Management 

Facilities under the RCRA Hazardous Waste Manifest System (Renewal),” OMB Control No. 

2050-0039, EPA ICR Number 0801.20. 

1B. Short Characterization 

Section 3002(a)(5) of the Resource Conservation and Recovery Act (RCRA) directs the U.S. 

Environmental Protection Agency (EPA) to “...establish requirements respecting...use of a 

manifest system and any other reasonable means necessary to assure that all such hazardous 

waste generated is designated for treatment, storage, or disposal, and arrives at treatment, 

storage, or disposal facilities...for which a permit has been issued...” Under this authority, EPA 

published regulations for a manifest system on February 26, 1980 (45 FR 12724). EPA 

established requirements for manifest completion, transmittal, and recordkeeping for hazardous 

waste generators at 40 CFR Part 262, Subpart B, for transporters at Part 263, Subpart B, and for 

treatment, storage, and disposal facilities (TSDFs) at Parts 264 and 265, Subpart E. EPA also 

requires the use of the Uniform Hazardous Waste Manifest (UHWM or manifest). These 

manifest requirements have been amended on several occasions. 

On February 7, 2014, EPA published the electronic manifest (e-Manifest) final rule (79 FR 

7518). The final rule established new manifest requirements that authorized the use of electronic 

manifests (or e-Manifests) as a means to track off-site shipments of hazardous waste from a 

generator's site to the site of the receipt and disposition of the hazardous waste. EPA is taking 

action now to establish the national e-Manifest system, but unknown variables (e.g., funding 

contingencies for e-Manifest system development) could delay the actual deployment of the 

system. Therefore, until EPA announces that the e-Manifest system is available for use in a 

subsequent Federal Register document, all respondents under the information collection 

requirements covered in this ICR must continue to comply with the current paper-based manifest 

system and use the existing paper manifest forms for the off-site transportation of hazardous 

waste shipments. EPA anticipates that the initial system will become available for use no later 

than the spring of 2018. 

This ICR requests a three-year extension of ICR 801. This supporting statement describes the 

paper-based manifest requirements in Sections 1 through 5. In Section 6, EPA estimates the 

hour and cost burden to respondents and EPA under these requirements. When EPA publishes 

the Federal Register notice announcing that the e-Manifest system is available for use, EPA 

intends to modify this ICR to describe the e-Manifest requirements and associated burden to 

respondents and EPA. 
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2. NEED, AUTHORITY & USE FOR THE INFORMATION 

2A. Need & Authority to Collect Information 

EPA’s authority to require use of a hazardous waste manifest system stems primarily from 

section 3002(a)(5) of RCRA, as discussed in Section 1B. See also RCRA sections 3003(a)(3) 

and 3004. The manifest serves an essential role as a control and transport document that 

accompanies the waste from its generation site to its treatment, storage, or disposal site. Among 

other things, the manifest lists the wastes that are being shipped and the TSDF to which the 

wastes are bound. The term “manifest system” refers to the overall set of requirements for the 

use of the manifest. 

The RCRA manifest requirements are needed to ensure that hazardous waste designated for 

delivery to an off-site TSDF actually reaches its destination. Thus, the manifest system serves as 

a self-enforcing mechanism that requires generators, transporters, and owner/operators of TSDFs 

to participate in an active hazardous waste tracking system. This system does not ordinarily 

involve intervention on the part of EPA unless hazardous wastes do not reach their designated 

point of disposal within a specified timeframe. 

The critical components of the manifest system include the information required on the manifest 

itself, the transmittal of manifest copies to specified parties, the submission of exception, 

discrepancy, and un-manifested waste reports to EPA, and recordkeeping requirements. Each of 

these components assists in tracking the waste and helps the Agency in reviewing whether 

hazardous waste shipments have been handled properly. The manifest, by incorporating U.S. 

Department of Transportation (DOT) requirements applicable to shipping papers, also serves as 

an important safety tool. In the event of an accident during transport or delivery, information on 

the manifest, such as the identification of the waste's hazard class, can be used to help response 

teams determine appropriate response actions. 

Although the generators, transporters, TSDFs, and emergency response teams (in the case of 

accidents) are the primary users of these records, EPA may review these documents during a 

facility inspection to make sure proper records are being kept and regulations are complied with. 

EPA also reviews and responds to exception reports, discrepancy reports, and un-manifested 

waste reports. 

2B. Practical Utility & Users of the Information 

The manifest serves a number of vital uses to industry, regulators, EPA and the public. For 

example, it: 

 Is a chain-of-custody document used by industry and regulators to track each 

shipment of hazardous waste from the generator to designated facility. Generators 

receive a copy of the manifest returned by the designated TSDF to confirm receipt of 

shipment. Each waste handler involved in the shipment keeps a copy and thus can be 

held accountable for proper handling and shipment. 
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 Provides information requirements sufficient to allow the use of a manifest in lieu of 

a United States Department of Transportation (USDOT) shipping paper or bill of 

lading, thereby reducing the duplication of paperwork to the regulated community. 

 Provides information to transporters and waste management facility workers on the 

hazardous properties of the waste. When a waste is received at the designated TSDF, 

fingerprint analyses are performed to ensure that the shipped wastes match the 

manifest (e.g., the facility may check for color, specific gravity, etc.). If a significant 

discrepancy between the waste and manifest is found, the designated TSDF needs to 

contact the generator to determine next steps (e.g., proper disposition of the waste). 

In this respect, the manifest facilitates the safe and proper handling, treatment, storage 

and disposal of the shipped wastes before and after TSDF acceptance. 

 Informs emergency response teams of the waste's hazard in the event of an accident, 

spill, or leak. 

 Can be used by regulators and the public to learn about shipments of hazardous 

wastes to and from generators and designated TSDFs. Some States collect manifests 

to assess fees to waste handlers. In addition, generators and TSDFs often use 

manifest data as an input into the development of the Biennial Reports, which are 

required under Parts 262, 264, and 265. These Biennial reports are made public by 

EPA. 

3. NONDUPLICATION, CONSULTATIONS & OTHER COLLECTION CRITERIA 

3A. Nonduplication 

No document identical or similar in purpose to the manifest is required by the Federal 

government for the shipment of RCRA hazardous waste. Although a USDOT hazardous 

materials shipping paper1

 contains most of the information contained on the manifest, it does not 

appear to be legally sufficient to track hazardous waste shipments from the generator to the 

designated facility (i.e. from “cradle-to-grave”). For example, USDOT’s shipping paper does 

not require EPA ID numbers and signatures of the transporters and all other chain-of-custody 

entities involved in shipping or handling the hazardous waste. EPA requires such signatures and 

identification numbers on the manifest to ensure accountability of each waste handler during 

shipment of the hazardous waste. Also, since EPA coordinated the development of the manifest 

with USDOT, the manifest form can be used as a USDOT shipping paper, thus eliminating the 

need for the transporter to carry both documents. Furthermore, the manifest form was developed 

as a means of standardizing the information requirements, both Federal and State, thereby 

 

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 Any person who offers a hazardous material for transportation in commerce must describe the hazardous material 

on a USDOT shipping paper in the manner required in 49 CFR Part 172, Subpart C. A shipping paper includes “a 

shipping order, bill of lading, manifest or other shipping document serving a similar purpose and containing the 

information required by 49 CFR 172.202, 172.203 and 172.204.” 49 CFR 171.8 provides a definition of “shipping 

paper.” 49 CFR 172.205(h) states that an EPA RCRA hazardous waste manifest (EPA Form 8700-22) “may be used 

as the shipping paper” if it contains all the information required by 49 CFR Part 172, Subpart C. 
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eliminating the need for a generator to complete and a transporter to carry multiple manifests for 

interstate shipments. 

3B. Public Notice 

In compliance with the Paperwork Reduction Act of 1995, EPA solicited public comments on 

this ICR through an announcement in the Federal Register on February 17, 2015 (80 FR 8306). 

No comments were received. 

3C. Consultations 

In preparing ICR 801.20, EPA contacted three representatives of TSDFs to request their 

feedback on its burden estimates. These individuals were contacted because their facilities are 

involved in multi-state shipping activities, interact with the entire range of waste handlers on 

manifest-related issues (e.g., manifest preparation, transmittal, recordkeeping), and stay abreast 

of trends of the manifest regulations and RCRA regulations generally. As such, they can speak 

knowledgeably about the respective activities and burdens of small and large generators, 

transporters, and TSDFs. These individuals were contacted in April 2015 and are identified in the 

table. 

Name Organization Phone Email 

Baker, Tom Veolia Environmental 

Services 973-691-7330 tom.baker@veolia.com 

Sauvageau, 

Matthew Clean Harbors 847-468-6701 sauvageau.matthew@cleanharbors.com 

Sloat, David Stericycle 412 585-4154 david.sloat@stericycle.com 

These individuals were shown the ICR’s hourly burden estimates for the following manifesting 

activities and asked if they are acceptable (i.e., representative as an industry average):2

 Preparing a manifest. 

 Preparing a continuation sheet. 

 Sending the manifest by mail to another waste handler. 

 Placing a manifest copy in the files for recordkeeping (generators). 

 Placing a manifest copy in the files for recordkeeping (TSDFs). 

 Preparing and submitting an exception report. 

They were also asked to suggest alternative estimates if the ICR’s estimates were not acceptable. 

All three individuals indicated that the ICR’s estimates are acceptable and no alternative 

estimates were offered. 

In addition, they were asked about the accuracy of the ICR’s estimate that 18% of SQGs are 

operating under reclamation agreements pursuant to 40 CFR 262.20(e). SQGs operating under 

these agreements are exempt from the requirement for a manifest. We heard from one individual 

who estimated 20% and another who estimated 14%; however, both believe the ICR’s estimate 

 

2

 The burden estimates were taken from the respondent exhibits of Section 6D of this document. 
5

of 18% is reasonable. A third individual indicated that his customers are not typically involved 

with reclamation agreements and therefore he is unable to provide an estimate or verify EPA’s 

estimate. However, he suspects that 18% is much too high when considering the overall 

universe of SQGs. 

Based on this feedback, EPA has decided not to revise the ICR’s estimate of 18%. First, EPA 

notes that the ICR’s estimate is not far from the two estimates received (14% and 20%), which 

suggests some level of agreement. In addition, two of the individuals believe the ICR’s estimate 

is reasonable. Finally, the individual who expressed doubt about the ICR’s estimate was unable 

to provide an alternative estimate. 

3D. Effects of Less Frequent Collection 

Under normal conditions, EPA does not collect manifests, but requires instead preparation of the 

manifest, use of the manifest during transportation, and recordkeeping of the manifests for a 

three-year period. Manifests are only collected by EPA either to accompany an exception or 

discrepancy report or in the case of an export. 

In addition, since the manifest is required to accompany all shipments of hazardous waste when 

shipped off-site by the generator, less frequent preparation is not possible. The frequency of offsite shipment is determined by the generator and depends on: (1) the quantities of waste to be 

shipped as they impact the economies of shipment; (2) transporter scheduling; and (3) the 

applicable regulatory requirements. The present system gives the generator the opportunity to 

maximize the economies of off-site shipments by selecting a shipping frequency that is 

appropriate for the rate of waste generation. Further, by requiring a manifest to accompany each 

shipment, EPA ensures the manifest is available in the case of a discharge of hazardous waste 

during transportation. Information on the manifest could be useful to emergency response 

personnel responding to the scene. In this regard, less frequent manifesting could result in a less 

expedient or protective response to the release. 

Note, however, that EPA provides a manifest exemption at 40 CFR 262.20(e) and (f) for 

specified types of shipments, as appropriate. Under section 262.20(e), small quantity generators 

(SQGs), or those generators who generate between 100 and 1,000 kilograms/month of hazardous 

waste, can be exempt from manifest requirements if the waste is reclaimed under a contractual 

agreement that specifies the type of waste and frequency of shipments; the transporting vehicle is 

owned and operated by the reclaimer; and the generator retains a copy of the reclamation 

agreement for three years after termination or expiration of the agreement. Under section 

262.20(f), generators who transport hazardous wastes on a public or private right-of-way within 

or along the border of contiguous property under the control of the same person, even if such 

contiguous property is divided by a public or private right-of-way, are exempt from manifesting 

requirements. 

3E. General Guidelines 
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These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR Part 1320, Section 1320.5. 

3F. Confidentiality 

Section 3007(b) of RCRA and 40 CFR Part 2, Subpart B, which define EPA’s general policy on 

the public disclosure of information, contain provisions for confidentiality. 

3G. Sensitive Questions 

No questions of a sensitive nature are included in any of the information collection requirements. 

4. THE RESPONDENTS AND THE INFORMATION COLLECTED 

4A. Respondent Standard Industrial Classification Codes 

Following are the Standard Industrial Classification (SIC) codes and the North American 

Industry Classification System (NAICS) codes of facilities most likely subject to the 

requirements in this ICR. 

Industrial Sector SIC Code(s) NAICS Code(s) 

Agriculture, Forestry, Fishing, and Hunting 01-09 11 

Mining 10-14 21 

Utilities 49 22 

Construction 15-17 23 

Manufacturing 20-39 31-33 

Wholesale Trade 50-51 42 

Retail Trade 52-59 44-45 

Transportation and Warehousing 40-47 48-49 

Information 27, 48, 73 (partial), 78 51 

Waste Management & Remediation Services 1799, 4953, 4959 562 

Public Administration 91-97 92 

4B. Information Requested 

There are four categories of respondents that will perform the information collections in this 

ICR, described below. This section describes the collections that apply to each category. 
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 Manifest printer registrant organizations – organizations that apply to EPA for 

approval to produce the paper manifest for use and distribution. 

 Hazardous waste generators – sites that generate hazardous waste and ship it off-site. 

 Hazardous waste transporters – entities that transport hazardous waste on public 

roads. 

 Designated treatment, storage and disposal facilities (designated TSDFs) – facilities 

that receive off-site shipments for management and disposal. Note that, normally, 

designated TSDFs also generate hazardous waste and therefore qualify as hazardous 

waste generators. 

Manifest Printer Registrant Organizations

(a) Applying to the Registry 

40 CFR 262.21(a) provides that a person may not print the manifest for use or distribution unless 

his/her organization (e.g., company, State agency) has received approval from EPA to do so 

under 40 CFR 262.21(c) and (e). In order to receive EPA approval, a registrant must submit to 

EPA an application that contains the information specified in 40 CFR 262.21(b). Upon EPA 

approval of the application, the registrant must submit three fully assembled manifests and, if 

needed, continuation sheets that meet the specifications of 40 CFR 262.21(f) and a description of 

the form samples, as specified in 40 CFR 262.21(d). In reviewing these submittals, EPA may 

request modification to them before approval. 

Data Items 

 An application that contains the following information: 

– Name and mailing address of registrant. 

– Name, telephone number, and email address of contact person. 

– Brief description of registrant’s government or business activity. 

– EPA ID number of the registrant, if applicable. 

– Description of the scope of the operations that the registrant plans to undertake in 

printing, distributing, and using its manifests, including: 

o A description of the printing operation. The description should include an 

explanation of whether the registrant intends to print its manifests 

in-house or through a separate printing company. If the registrant intends 

to use a separate printing company to print the manifest on its behalf, the 

application must identify this printing company and discuss how the 

registrant will oversee the company. If this includes the use of 

intermediaries, the role of each must be discussed. The application must 

provide the name and mailing address of each company. It also must 

provide the name and telephone number of the contact person at each 

company. 

o A description of how the registrant will ensure that its organization and 

unaffiliated companies, if any, comply with the requirements of 40 CFR 

262.21. The application must discuss how the registrant will ensure that a 

unique manifest tracking number will be pre-printed on each manifest. 
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The application must describe the internal control procedures to be 

followed by the registrant and unaffiliated companies to ensure that 

numbers are tightly controlled and remain unique. If computer systems or 

other infrastructure will be used to maintain, track, or assign numbers, 

these should be indicated. The application must indicate how the printer 

will pre-print a unique number on each form. The application must explain 

the quality procedures to be followed by each establishment and printing 

company to ensure that all required print specifications are consistently 

achieved and that printing violations are identified and corrected at the 

earliest practicable time. 

o An indication of whether the registrant intends to use the manifests for its 

own business operations or to distribute the manifests to a separate 

company or to the general public (e.g., for purchase). 

– A brief description of the qualifications of the company that will print the 

manifest. The registrant may use readily available information to do so (e.g., 

corporate brochures, product samples, customer references, documentation of ISO 

certification), so long as such information pertains to the establishments or 

company being proposed to print the manifest. 

– Proposed unique three-letter manifest tracking number suffix. If the registrant is 

approved to print the manifest, the registrant must use this suffix to pre-print a 

unique manifest tracking number on each manifest. 

– A signed certification by a duly authorized employee of the registrant that the 

organizations and companies in its application will comply with the procedures of 

its approved application and the requirements of 40 CFR 262.21 and that it will 

notify EPA of any duplicated manifest tracking numbers on manifests that have 

been used or distributed to other parties as soon as this becomes known. 

 Three fully assembled manifests and, if needed, continuation sheets that meet all of 

the specifications in 40 CFR 262.21(f). The form samples must be printed by the 

company that will print the manifest as identified in the application approved under 

40 CFR 262.21(c). The registrant need not submit samples of the continuation sheet 

if the continuation sheet will be printed using the same paper type, paper weight, ink 

color of the instructions, and binding method as the manifest. 

 A description of the manifest samples as follows: 

– Paper type (i.e., manufacturer and grade of the manifest paper). 

– Paper weight of each copy. 

– Ink color of the manifest’s instructions. If screening of the ink was used, the 

registrant must indicate the extent of the screening. 

– Method of binding the copies. 

Respondent Activities 

 Prepare and submit initial application. 

 Submit revised initial application to EPA, if requested. 

 Submit three fully assembled manifests and, if needed, continuation sheets and a 

description of the form samples. 

 Submit revised form samples based on EPA comment on the initial samples, if 
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requested. 

(b) Updating General Information in the Approved Application 

40 CFR 262.21(h)(1) provides that, if an approved registrant would like to update any of the 

information provided in its application (e.g., to update a company phone number or name of 

contact person), the registrant must revise the application and submit it to EPA, along with an 

indication or explanation of the update, as soon as practicable after the change occurs. EPA will 

review and either approve or deny the revision. If the revision is denied, the registrant must 

respond to the Agency’s concerns. 

Data Item 

 Revised application, along with an indication or explanation of the update. 

Respondent Activities 

 Revise and submit the application to EPA, along with an indication or explanation of 

the update. 

 Respond to the Agency’s concerns, if applicable. 

(c) Requesting Approval for a New Tracking Number Suffix 

40 CFR 262.21(h)(2) provides that, if an approved registrant would like a new tracking number 

suffix, the registrant must submit a proposed suffix to EPA, along with the reason for requesting 

it. 

Data Item 

 Proposed tracking number suffix, along with the reason for requesting it. 

Respondent Activity 

 Submit a proposed tracking number suffix, along with the reason for requesting it. 

(d) Requesting Approval for Changes to Printing Specifications or Use of a New 

Printer 

40 CFR 262.21(h)(3) provides that, if a registrant would like to change the paper type, paper 

weight, ink color of the manifest instructions, or binding method of its manifest or continuation 

sheet subsequent to approval under 40 CFR 262.21(e), then the registrant must submit three 

samples of the revised form for EPA review and approval. If the approved registrant would like 

to use a new printer, the registrant must submit three manifest samples printed by the new 

printer, along with a brief description of the printer’s qualifications to print the manifest. In 

reviewing these submittals, EPA may request modification to them before approval. 
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Data Items 

 Three samples of the manifest form and/or continuation sheet. 

 A brief description of the qualifications of the new printer, if applicable. 

Respondent Activities 

 Submit three samples of the manifest form and/or continuation sheet and, if 

applicable, a brief description of the qualifications of the new printer. 

 Submit revised manifest form and/or continuation sheet samples to EPA, if requested. 

(e) Typesetting the Manifest Form Subsequent to its Approval 

40 CFR 262.21(i) provides that, if subsequent to its approval under 40 CFR 262.21(e), a 

registrant typesets its manifest or continuation sheet instead of using the electronic file of the 

forms provided by EPA, it must submit three samples of the manifest or continuation sheet to the 

registry for approval. The registrant cannot use or distribute its typeset forms until EPA 

approves them. 

Data Item 

 Three samples of the manifest or continuation sheet. 

Respondent Activity 

 Submit three samples of the manifest or continuation sheet to the registry for 

approval. 

(f) Requesting an Exemption 

40 CFR 262.21(j) provides that EPA may exempt a registrant from the requirement to submit 

form samples under 40 CFR 262.21(d) or 262.21(h)(3) if the Agency is persuaded that a separate 

review of the registrant’s forms would serve little purpose in informing an approval decision 

(e.g., a registrant certifies that it will print the manifest using the same paper type, paper weight, 

ink color of the instructions, and binding method of the form samples approved for some other 

registrant). A registrant may request an exemption from EPA by indicating why an exemption is 

warranted. 

Data Item 

 Documentation indicating why an exemption is warranted. 

Respondent Activity 

 Submit documentation to EPA indicating why an exemption is warranted. 
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(g) Notifying EPA of a Printing Specification Violation 

40 CFR 262.21(k) requires an approved registrant to notify EPA by phone or email as soon as it 

becomes aware that it has used or distributed manifests that contain duplicated manifest tracking 

numbers. 

Data Item 

 Notification of duplicated manifest tracking numbers. 

Respondent Activity 

 Notify EPA of duplicated manifest tracking numbers. 

(h) Revising the Approved Manifest if Requested by EPA 

40 CFR 262.21(l) provides that, if, subsequent to approval of a registrant under 40 CFR 

262.21(e), EPA becomes aware that the registrant’s approved form does not satisfactorily meet 

the print specifications in 40 CFR 262.21(f), EPA will contact the registrant and require 

modifications to the form. 

Data Item 

 Revised manifest form samples. 

Respondent Activity 

 Submit revised manifest form samples to EPA, if requested. 

(i) Responding to Suspension and Revocation Procedures 

40 CFR 262.21(m) provides that EPA may suspend and, if necessary, revoke printing privileges 

if it finds that the registrant: (i) has deviated from its application approved under 40 CFR 

262.21(c) in printing the form; (ii) has knowingly used or distributed forms that deviate from its 

approved form samples in regard to paper weight, paper type, ink color of the instructions, or 

binding method; or (iii) exhibits a continuing pattern of behavior in using or distributing 

manifests that contain duplicate manifest tracking numbers. EPA will send a warning letter to 

the registrant that specifies the date by which it must come into compliance with the 

requirements. If the registrant does not come in compliance by the specified date, EPA will send 

a second letter notifying the registrant that EPA has suspended or revoked its printing privileges. 

An approved registrant must provide information on its printing activities to EPA if requested. 

Data Item 

 Information requested by EPA. 
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Respondent Activity 

 Submit information if requested by EPA. 

Hazardous Waste Generators

(a) Manifest Completion 

40 CFR 262.20(a)(1) requires generators transporting, or offering for transportation, hazardous 

waste for off-site treatment, storage, or disposal to prepare a manifest (EPA Form 8700-22) and, 

if necessary, continuation sheets (EPA Form 8700-22A). In addition, generators must comply 

with other applicable sections of 40 CFR as applicable, including sections 262.20, 262.23, 

262.54, and 262.60, as appropriate, as well as the instructions in the appendix to 40 CFR Part 

262. 

Data Items 

 Manifest, which includes the following: 

– The generator’s EPA ID or State ID number. 

– The total number of pages used to complete the manifest. 

– The emergency response phone number. 

– The manifest tracking number. 

– The generator’s name and mailing address. 

– The generator’s phone number. 

– The generator’s site address (if different than mailing address). 

– The name and EPA ID number for transporters. 

– The designated facility’s name and site address. 

– The designated facility’s phone number. 

– The EPA ID number of the designated facility. 

– The USDOT description of the waste. 

– The container description (number and type). 

– The total quantity of each waste described. 

– The unit of measure. 

– The waste codes representing the waste. 

– Special handling instructions and additional information. 

– The generator’s/offeror’s certification.3

 For primary exporters only: The primary exporter must prepare the manifest in 

accordance with 40 CFR 262.20 and 262.23, except as provided under 40 CFR 

262.54(a) through (d): 

 

3

 The generator’s/offeror’s certification in Item 15 of the manifest form references the waste minimization 

certification codified at 40 CFR 262.27. 
13

– In lieu of the site name, site address and EPA ID number of the designated 

permitted facility, enter the name and site address of the consignee. 

– In lieu of the name, site address, and EPA ID number of a permitted alternate 

facility, enter the name and site address of any alternate consignee. 

– In the International Shipments Block, check the export box and enter the point of 

exit (city and State) from the US. 

 For primary importers only: The primary importer must prepare the manifest in 

accordance with 40 CFR 262.20 & 262.23, except as provided in 40 CFR 262.60(b) 

and (d): 

– In place of the generator’s name, address, and EPA ID number, use the name and 

address of the foreign generator and the importer’s name, address, and EPA ID 

number. 

– In place of the generator’s signature on the certification statement, the US 

importer or his agent must sign and date the certification and obtain the signature 

of the initial transporter. 

– In the International Shipment Block, check the import box and enter the point of 

entry (city and State) into the US. 

Respondent Activities 

 Generators perform the following: 

– Complete the manifest for domestic, export, and import shipments; and 

– Complete continuation sheet, if required. 

(b) Compliance with State Program Requirements 

Under 40 CFR 262.21(g)(2), generators must determine whether the consignment State regulates 

any additional wastes (beyond those regulated Federally) as hazardous wastes under its State 

hazardous waste program. Generators must also determine whether the consignment State or 

generator State requires the generator to submit any copies of the manifest to these States. 

Data Item 

 Information provided by the State on its manifest program. 

Respondent Activities 

 Generators must contact the consignment/generator State if needed and submit any 

copies of the manifest to these States, as applicable. 

(c) Manifest Transmittal and Recordkeeping 

Generators must transmit and keep records of the manifest in accordance with 40 CFR 262.23, 

262.40, 262.44, 262.54 and 262.60, as appropriate. A generator must sign and give copies of the 

manifest to the transporter along with the hazardous waste in accordance with 40 CFR 262.23(a) 
14

and (b) and retain copies of the manifest in accordance with 40 CFR 262.23(a) & 262.40(a). For 

shipments of hazardous waste within the US solely by water (bulk shipments only), the 

generator, as required by 40 CFR 262.23(c), must send three copies of the manifest to the 

owner/operator of the designated facility or the last water transporter to handle the waste in the 

US if exported by water. For rail shipments of hazardous waste within the US which originate at 

the site of generation, the generator, as required under 40 CFR 262.23(d), must send at least three 

copies of the manifest to the next non-rail transporter, the designated facility, or the last rail 

transporter to handle the waste in the US if exported by rail. For exports, the primary exporter 

must provide the transporter with a EPA Acknowledgment of Consent, and an additional copy of 

the manifest or shipping papers for delivery to the US Customs official at the point the hazardous 

waste exits the US, as required by 40 CFR 262.54(h) and (i). In the event an SQG’s waste is 

reclaimed under a contractual agreement pursuant to 40 CFR 262.20(e)(1), the SQG must retain 

the reclamation agreement for at least three years from the date of termination or expiration of 

the agreement, as required by 40 CFR 262.20(e)(2). 

Data Items 

 Manifest. 

 Acknowledgement of Consent for exports. 

 Reclamation agreement for SQG tolling arrangements. 

Respondent Activities 

 Generators must perform the following: 

– Sign the manifest certification and obtain the signature of the initial transporter 

and date of acceptance on the manifest in accordance with 40 CFR 262.23(a). 

– Keep a copy of the manifest and give the remaining copies to the initial 

transporter, in accordance with 40 CFR 262.23(a) & (b). 

– Keep a copy of the manifest returned from the designated facility for at least three 

years from the date the waste was accepted by the initial waste transporter, in 

accordance with 40 CFR 262.40(a) or 262.44(a). 

– For shipments solely by water, send three copies of the manifest, dated and signed 

in accordance with 40 CFR 262.23(a), to the designated facility or the last water 

transporter to handle the waste in the US, as required by 40 CFR 262.23(c). 

[Note: Copies of the manifest are not required for each transporter.] 

– For shipments by rail originating at the site of generation, send at least three 

copies of the manifest to the next non-rail transporter, the designated facility, or 

the last rail transporter to handle the waste in the US, as required by 40 CFR 

262.23(d). 

 Primary exporters must provide the transporter with an EPA Acknowledgment of 

Consent and an additional copy of the manifest or shipping papers for delivery to the 

US Customs official at the point the hazardous waste exits the US, as required by 40 

CFR 262.54(h) and (i). 

 An SQG operating under a tolling agreement must retain a copy of each reclamation 
15

agreement, if applicable, for at least three years after the termination or expiration of 

the agreement, as required by 40 CFR 262.20(e)(2). 

(d) Undeliverable Shipments 

Generators must provide instructions to the transporter on how to deal with shipments that 

cannot be delivered to the designated or the alternate TSDF. For shipments that a transporter is 

unable to deliver to the designated facility or the alternate facility, generators must designate 

another facility or instruct the transporter to return the waste, as required by 40 CFR 262.20(d) 

and 262.54(g)(3). 

Data Item 

 Instructions to the transporter on how to deal with shipments that cannot be delivered 

to the designated or the alternate TSDF. 

Respondent Activity 

 For shipments that a transporter is unable to deliver to the designated facility or the 

alternate facility, generators must designate another facility or instruct the transporter 

to return the waste. 

(e) Rejected Waste and Container Residues 

Under 40 CFR 262.34(j), a generator who sends a shipment of hazardous waste to a designated 

facility with the understanding that the designated facility can accept and manage the waste and 

later receives that shipment back as a rejected load or residue in accordance with the manifest 

discrepancy provisions of 40 CFR 264.72 or 265.72 may accumulate the returned waste on-site, 

as specified. Upon receipt of the returned shipment, the generator must sign the manifest that 

accompanies the rejected load or residue. 

Data Item 

 A manifest. 

Respondent Activities 

 Generators must perform the following activities: 

– Sign Item 18c of the manifest, if the transporter returned the shipment using the 

original manifest. 

– Sign Item 20 of the manifest, if the transporter returned the shipment using a new 

manifest. 

– Provide the transporter a copy of the manifest. 

– Within 30 days of delivery, send a copy to the designated TSDF that returned the 

shipment to the generator. 

– Retain a copy. 
16

(f) Exception Reports: Completion, Submission, and Recordkeeping 

(f1) Large Quantity Generators

In the event an LQG does not receive a copy of the signed manifest from the designated facility 

owner/operator within 35 days of the date the waste was accepted by the initial transporter, the 

LQG must contact the transporter and/or the owner/operator of the designated facility to 

determine the status of the hazardous waste. The LQG must submit an exception report to EPA 

if he/she has not received a copy of the signed manifest from the designated facility 

owner/operator within 45 days of the date the waste was accepted by the initial transporter and 

must retain a copy of the exception report for at least three years from the due date of the report, 

in accordance with 40 CFR 262.42(a) and 262.40(b). 

Data Item 

 An exception report containing the following data: 

– A legible copy of the manifest for which the generator does not have confirmation 

of delivery, as required by 40 CFR 262.42(a)(2)(i). 

– A cover letter signed by the generator or his authorized representative explaining 

the efforts taken to locate the hazardous waste and the results of those efforts, as 

required by 40 CFR 262.42(a)(2)(ii). 

Respondent Activities 

 LQGs must perform the following: 

– Prepare and submit a signed cover letter to EPA explaining the generator’s efforts 

to locate the hazardous waste and the results of those efforts, along with a legible 

copy of the manifest, in accordance with 40 CFR 262.42(a)(2)(i) and (ii). 

– Keep a copy of each exception report, as required by 40 CFR 262.40(b). 

(f2) Small Quantity Generators

In the event an SQG does not receive a copy of the signed manifest from the owner/operator of 

the designated facility within 60 days of the date the waste was accepted by the initial 

transporter, he/she must submit to the EPA Regional Administrator a legible copy of the 

manifest with some indication that he has not received confirmation of delivery, in accordance 

with 40 CFR 262.42(b). 

Data Item 

 A legible copy of the manifest with some indication that the SQG has not received 

confirmation of delivery. 
17

Respondent Activity 

 SQGs must submit a legible copy of the manifest with some indication that the waste 

has not been delivered. 

Hazardous Waste Transporters

(a) Manifest Completion, Transmittal, and Recordkeeping 

40 CFR 263.20, 263.21 & 263.22 detail the completion, transmittal, and recordkeeping 

requirements of manifests or shipping papers for hazardous waste transporters, including those 

exporting hazardous waste outside the US. 

(a1) Hazardous Waste Transporters (except as exempted by 40 CFR 263.20(e) and (f))

40 CFR 263.20(a)(1) provides that a transporter may not accept hazardous waste from a 

generator unless the transporter is also provided with a manifest form (EPA Form 8700-22, and 

if necessary, EPA Form 8700-22A) signed in accordance with the requirement of section 262.23. 

Except for certain water and rail transporters exempted under 40 CFR 263.20(e)&(f), 

transporters transporting hazardous waste outside the US (40 CFR 263.20(g)) and transporters 

transporting hazardous waste pursuant to a reclamation agreement (40 CFR 263.20(h)), section 

263.20(b), (c),(d) require transporters to sign and date the manifest acknowledging acceptance of 

the waste from the generator before transporting the hazardous waste. Before leaving the 

property, the transporter must return or transmit a signed copy of the manifest to the generator. 

In addition, the transporter must ensure that a copy of the manifest or other shipping paper 

accompanies the shipment and is readily available and recognizable. 

A transporter who delivers a hazardous waste to another transporter or to the designated facility 

must obtain the date of delivery and the signature of the transporter or designated facility; retain 

a copy in accordance with 40 CFR 263.22; and give the remaining copies of the manifest to the 

accepting transporter or designated facility, as required at 40 CFR 263.20(d). 

Data Item 

 A manifest. 

 A shipping paper. 

Respondent Activities 

 Transporters must perform the following; 

– Sign and date the manifest, as required by 40 CFR 263.20(b). 

– Return a signed copy of the manifest to the generator, as required under 40 CFR 

263.20(b). 

– Ensure that the manifest (or other shipping paper) accompanies the waste to its 

destination, as required by 40 CFR 263.20(c). 
18

– In delivering the hazardous waste and manifest to another transporter or to the 

designated facility, perform the following activities, as required by 40 CFR 

263.20(d): 

o Obtain the date of delivery and signature of that transporter or the 

owner/operator of the facility or alternate facility designated on the 

manifest, pursuant to 40 CFR 263.20(d)(1). 

o Retain a copy of the manifest pursuant to 40 CFR 263.22(a). 

o Give remaining copies of the manifest to the accepting transporter or 

facility, in accordance with 40 CFR 263.20(d)(3). 

(a2) Water (Bulk Shipment) Transporters Regulated under 40 CFR 263.20(e)

Water (bulk shipment) transporters who are regulated under 40 CFR 263.20(e) must sign and 

date the manifest upon receipt of the hazardous waste; must ensure that a shipping paper 

containing the generator, waste, and facility information, and a EPA Acknowledgment of 

Consent for exports, accompany the waste during transportation; must obtain the signature of the 

facility owner/operator on the manifest or shipping paper; and must retain a copy of the manifest 

or shipping paper for three years. 

Data Items 

 Manifest. 

 Copies of the shipping paper containing all the information on the manifest except the 

EPA ID numbers, the generator certification, and required signatures, as required 

under 40 CFR 263.20(e). 

 An EPA Acknowledgment of Consent (for exporters only), as required by 40 CFR 

263.20(e)(2). 

Respondent Activities 

 The person delivering hazardous waste to the initial water transporter must: 

– Obtain the date of delivery and signature of the initial water transporter on the 

manifest, in accordance with 40 CFR 263.20(e)(4). 

– Forward the manifest to the designated facility, in accordance with 40 CFR 

263.20(e)(4). 

 Bulk water transporters subject to section 263.20(e) must perform the following 

activities: 
19

– Ensure that the shipping paper (and Acknowledgment of Consent, for exports) 

accompanies the waste to its destination, as required by 40 CFR 263.20(e)(2). 

– If the delivering (water) transporter, obtain the date of delivery and signature of 

the owner/operator of the designated facility on either the manifest or shipping 

paper, as required by 40 CFR 263.20(e)(3). 

– If the initial water transporter, sign and date the manifest and return it to the 

delivering transporter so that the manifest can be forwarded to the designated 

facility owner/operator, as required by 40 CFR 263.20(e)(4). 

– Retain a copy of the manifest or shipping paper, as required by 40 CFR 263.22(b). 

(a3) Rail Transporters Regulated under 40 CFR 263.20(f)

Under 40 CFR 263.20(f)(1), initial rail transporters must sign and date the manifest 

acknowledging acceptance of the hazardous waste; return or transmit a signed copy of the 

manifest to the non-rail transporter; and forward at least three copies of the manifest to the next 

non-rail transporter, the designated facility, if the shipment is delivered to that facility by rail, or 

the last rail transporter designated to handle the waste in the US; and retain a copy of the 

manifest and rail shipping paper in accordance with 40 CFR 263.22. 

Rail transporters must ensure that a shipping paper containing all the information required on the 

manifest (excluding the EPA ID numbers, generator certification, and signatures) and, for 

exports, a EPA Acknowledgment of Consent accompanies the hazardous waste at all times, as 

required by 40 CFR 263.20(f)(2). When delivering hazardous waste to the designated facility, a 

rail transporter must obtain the date of delivery and signature of the owner or operator of the 

designated facility on the manifest, or a signature on the shipping paper (if the manifest has not 

been received by the facility) and retain a copy of the manifest or signed shipping paper, as 

required under 40 CFR 263.20(f)(3). When delivering hazardous waste to a non-rail transporter, 

a rail transporter must obtain the date of delivery and the signature of the next non-rail 

transporter on the manifest and retain a copy of the manifest, as required under 40 CFR 

263.20(f)(4). Before accepting hazardous waste from a rail transporter, a non-rail transporter 

must sign and date the manifest and provide a copy to the rail transporter, as required by 40 CFR 

263.20(f)(5). 

Data Items 

 A manifest. 

 A shipping paper containing all the information on the manifest, except the EPA ID 

numbers, the generator certification, and required signatures. 

 An EPA Acknowledgment of Consent (for exports only). 

Respondent Activities 

 When accepting waste from a non-rail transporter, sign and date the manifest, as 

required by 40 CFR 263.20(f)(1)(i) and return or transmit a signed copy of the 

manifest to the non-rail transporter, as required by 40 CFR 263.20(f)(1)(ii). 

 Forward at least three copies of the manifest to either the next non-rail transporter, the 
20

designated facility, or the last rail transporter designated to handle the waste in the 

US, as required by 40 CFR 263.20(f)(1)(iii). 

 Ensure a shipping paper containing all the information required on the manifest 

excluding the EPA ID number, generator certification, and signatures (and for exports 

an Acknowledgment of Consent) accompanies the waste, as required under 40 CFR 

263.20(f)(2). 

 When delivering hazardous waste to the designated facility or to the next non-rail 

transporter, obtain the signature and date of delivery of the facility or non-rail 

transporter on the manifest, as required under 40 CFR 263.20(f)(3)(i) or (f)(4)(i). 

 Retain a copy of the manifest and/or rail shipping paper, as required under 40 CFR 

263.20(f)(1)(iv), 263.20(f)(3)(ii), 263.20(f)(4)(ii) and 263.22, as applicable. 

 Before accepting hazardous waste from a rail transporter, sign and date the manifest 

and provide a copy to the rail transporter, as required under 40 CFR 263.20(f)(5). 

(a4) Transporters Who Import or Export Hazardous Wastes (40 CFR 263.20(g) & (i))

Under 40 CFR 263.20(g), transporters who either transport hazardous waste into (import) or out 

of (export) the US, must sign and date the manifest to indicate the date that the shipment arrived 

at (import) or left (export) the US, respectively; retain one copy in accordance with 40 CFR 

263.22; for exports return a signed copy to the generator and provide a copy of the exported 

waste manifest to a US Customs official at the point of departure from the US. In addition for 

exports, the transporter also must ensure that a copy of the EPA Acknowledgment of Consent 

accompanies the waste, as required by 40 CFR 263.20(a). 

Data Items 

 A manifest. 

 Shipping paper. 

 EPA Acknowledgment of Consent. 

Respondent Activities 

 For imports and exports, sign and date the manifest in the International Shipments 

block to indicate the date that the shipment entered or left the US, respectively, as 

required by 40 CFR 263.20(g)(1). 

 For imports and exports, retain a copy of the manifest, as required by 40 CFR 

263.20(g)(2). 

 For exports, return a signed copy of the manifest to the generator, as required by 40 

CFR 263.20(g)(3). 

 For exports, give a copy of the manifest to a US Customs official at the point of 

departure from the US, as required by 40 CFR 263.20(g)(4). 

 For exports, ensure that copies of the manifest and EPA Acknowledgment of Consent 

accompanies the waste, as required by 40 CFR 263.20(a).
21

(a5) Transporters Who Transport Hazardous Waste Pursuant to a Reclamation 

Agreement (263.20(h))

40 CFR 263.20(h) provides that transporters can be exempt from the requirements of 40 CFR 

263.20 & 263.22 when transporting a SQG’s waste pursuant to a reclamation agreement in 

accordance with 40 CFR 262.20(e). These transporters are required to record data items on a log 

or shipping papers, carry the record to the reclamation facility, and retain these records, as 

required by 40 CFR 263.20(h). 

Data Items 

 A reclamation agreement that includes the following 

– The name, address, and EPA ID number of the hazardous waste generator. 

– The quantity of waste accepted. 

– All USDOT-required shipping information. 

– The date the waste is accepted. 

Respondent Activities 

 Record the waste information on a log or shipping paper, as required by 40 CFR 

263.20(h)(2). 

 Carry the record when transporting waste to the reclamation facility, as required by 

40 CFR 263.20(h)(3). 

 Retain the records for at least three years after termination or expiration of the 

agreement, as required by 40 CFR 263.20(h)(4). 

(a6) Undeliverable Shipments 

Under 40 CFR 263.21(a), the transporter must deliver the entire quantity of hazardous waste 

which he has accepted from a generator or a transporter to the designated facility listed on the 

manifest; the alternate designated facility, the next designated transporter; or the place outside 

the US designated by the transporter. 40 CFR 263.21(b)(1) requires that, if the hazardous waste 

cannot be delivered in accordance with 40 CFR 263.21(a) because of an emergency condition 

other than rejection of the waste by the designated facility, then the transporter must contact the 

generator for further directions and must revise the manifest according to the generator’s 

instructions. 

Data Item 

 A manifest that has been revised according to the generator’s instructions. 

Respondent Activity 

 Contact the generator for further directions and revise the manifest according to the 

generator’s instructions. 
22

(a7) Rejected Waste and Container Residues 

Under 40 CFR 263.21(b)(2), if a hazardous waste is rejected or a container residue is identified 

by the designated facility listed on the manifest while the transporter is on the facility’s premises, 

then the transporter must comply with the appropriate procedures: 

 Partial load rejections: The transporter must obtain the facility’s signature and date, 

the manifest tracking number of the new form, and a description/indication of the 

rejected waste in the discrepancy block on the original manifest. The transporter 

must retain this copy of the manifest in accordance with 40 CFR 263.22 and give the 

remaining copies to the designated facility. If the transporter is forwarding the 

shipment to the alternate facility or returning it the generator, the transporter must 

obtain the new manifest for the shipment. 

 Full load rejections or container residues: The transporter must obtain the original 

manifest that includes the facility’s signature and date, name and address of the 

alternate facility or generator, and a description of the rejected load or container 

residue in the discrepancy block as appropriate. The transporter must retain this copy 

of the manifest in accordance with 40 CFR 263.22 and give a copy to the facility. If 

the original manifest is not used, then the transporter must obtain a new manifest for 

the shipment. 

Data Item 

 A manifest. 

Respondent Activities 

 For partially rejected loads made while the transporter is on site, obtain the amended 

manifest from the facility, keep a copy, and, if receiving the rejected waste, obtain the 

new manifest. 

 For fully rejected loads made or container residues identified while the transporter is 

on site, obtain the original manifest, as amended, from the facility. 

(b) Notification of Discharge of Hazardous Waste 

In the event of a discharge of hazardous waste during transportation, 40 CFR 263.30(a) requires 

the transporter to take appropriate immediate action to protect human health and the 

environment, for example, notifying local authorities. 40 CFR 263.30(c) requires an air, rail, 

highway, or water transporter who has discharged hazardous waste to give notice, if required by 

49 CFR 171.15, to NRC and to report in writing to USDOT as required by 49 CFR 171.16. 40 

CFR 263.30(d) requires a water (bulk shipment) transporter who has discharged hazardous waste 

to give the same notice as required by 33 CFR 153.203 for oil and hazardous substances, if not 

already required under 33 CFR 153.203. Water (bulk shipment) transporters, as soon as they 

have knowledge of any discharge of hazardous waste, must immediately notify NRC, US Coast 

Guard, as required by 33 CFR 153.203. If the direct reporting to the NRC is not practicable, 
23

reports may be made to the US Coast Guard or EPA predesignated OSC for the geographic area 

where the discharge occurs. If it is not possible to notify the NRC or the predesignated OSC 

immediately, reports may be made immediately to the nearest US Coast Guard unit, provided the 

transporter notifies the NRC as soon as possible. 

Data Item 

 Notification of a discharge of hazardous waste. 

Respondent Activities 

 In the event of a discharge of hazardous waste during transportation, the transporter 

must take appropriate action to protect human health and the environment, including 

notification of the discharge to local authorities, as required by 40 CFR 263.30(a). 

 Water (bulk shipment) transporters must immediately notify NRC of the discharge or, 

if it is not practicable to notify the NRC, a predesignated OSC can be notified. If the 

OSC is notified, the transporter must notify the NRC of the discharge as soon as 

possible, as required by 40 CFR 263.30(d) and 33 CFR 153.203. 

Designated Treatment, Storage and Disposal Facilities 

(a) Transmitting the Manifest and Reporting to EPA 

(a1) Manifest Completion, Transmittal and Recordkeeping 

40 CFR 264.71(a),(b) and 40 CFR 265.71(a),(b) set forth completion, transmittal, and 

recordkeeping requirements for TSDFs that receive hazardous waste accompanied by a manifest 

or shipping paper. 40 CFR 264.71(a),(b) and 40 CFR 265.71(a),(b) provide that, if a facility 

receives hazardous waste accompanied by a manifest (or shipping paper, for certain rail or water 

shipments), the TSDF or his/her agent must sign and date each copy of the manifest to certify 

that the hazardous waste covered by the manifest was received; note any significant 

discrepancies in the manifest on each copy; immediately return to the transporter a signed copy; 

within 30 days of delivery send a copy of the manifest to the generator or EPA’s Office of 

Enforcement and Compliance Assurance (for imports); and retain a copy for at least three years 

from the date of delivery. 

Data Item 

 Manifest. 

 Shipping paper. 

Respondent Activities 

 Complete, transmit, and retain copies of the manifest, as required by 40 CFR 

264.71(a),(b) or 40 CFR 265.71(a),(b) and the manifest instructions: 
24

– Enter the name of the person accepting the waste and sign and date each copy of 

the manifest (or shipping paper, if applicable). 

– Complete the management method codes. 

– Note any discrepancies (as defined in 40 CFR 264.72(a)) on each copy of the 

manifest (or shipping paper, if applicable). 

– Immediately give the transporter at least one copy of the manifest (or shipping 

paper). 

– Within 30 days of delivery, send a copy (Page 3) of the manifest to the generator. 

– If the facility receives hazardous waste imported from a foreign source, mail a 

copy of the manifest and documentation confirming EPA's consent to the import 

of hazardous waste to EPA’s Office of Enforcement and Compliance Assurance 

(OECA). 

– Retain a copy of the manifest (or shipping paper) for at least three years from the 

date of delivery. 

[Note: Although the noting of manifest or shipping paper discrepancies is mentioned 

above, it is burdened in the subsection entitled “Discrepancy Reports.”] 

(a2) Compliance with State Program Requirements 

Under 40 CFR 264.71(e) and 40 CFR 265.71(e), TSDFs must determine whether the 

consignment State for a shipment regulates any additional hazardous wastes (beyond those 

regulated Federally). TSDFs must also determine whether the consignment State or generator 

State requires the facility to submit any copies of the manifest to these States. 

Data Item 

 Information provided by the State on its manifest program. 

Respondent Activities 

 Contact the consignment/generator State if needed and submit any copies of the 

manifest to these States, as applicable. 

(a3) Discrepancy Reports 

40 CFR 264.72 and 265.72 provide that, upon discovering a significant discrepancy, TSDFs 

must attempt to reconcile the discrepancy with the waste generator or transporter. If the 

discrepancy is not resolved within 15 days after receiving the waste, the owner/operator must 

immediately submit to EPA a copy of the manifest or shipping paper in question, as well as a 

letter describing the discrepancy and attempts to reconcile it. 

Data Items 

 A copy of the manifest or shipping paper in question. 

 A letter describing the manifest discrepancy and the facility’s efforts to reconcile it. 
25

Respondent Activities 

 Attempt to reconcile any discrepancies, as required by 40 CFR 264.72(c) or 

265.72(c). 

 Prepare and submit a letter to EPA describing the discrepancy and attempts to 

reconcile it, along with a copy of the manifest or shipping paper at issue, as required 

by 40 CFR 264.72(c) or 265.72(c). 

(b) Rejected Waste and Container Residues 

40 CFR 264.72 and 40 CFR 265.72 provide that the TSDF must forward rejected waste or 

container residues to an alternate facility that can accept the waste. If the TSDF is unable to 

locate an alternate facility to take the waste, then the TSDF may return the shipment to the 

original generator. 40 CFR 264.72(d) through (g) and 40 CFR 265.72(d) through (g) describe 

manifest procedures for TSDFs that originate a rejected waste or container residue. 

(b1) Rejection of Waste after the Transporter Leaves the Facility 

For full or partial load rejections and residues that are to be sent off-site to an alternate facility or 

back to the generator after the transporter has left the facility, the facility is required to prepare a 

new manifest, as required by 40 CFR 264.72(d), (e)(1)-(6), or (f)(1)-(6) or 40 CFR 265.72(d), 

(e)(1)-(6), or (f)(1)-(6). 

In addition, if a facility rejects a waste or identifies a container residue that exceeds the quantity 

limits for “empty” containers set forth in 40 CFR 261.7(b) after it has signed, dated, and returned 

a copy of the manifest to the transporter, the facility must comply with 40 CFR 264.72(g) or 

265.72(g). The facility must amend its copy of the manifest to indicate the rejected wastes or 

residues in the discrepancy space of the amended manifest. The facility must also copy the 

manifest tracking number from Item 4 of the new manifest to the Discrepancy space of the 

amended manifest, and must re-sign and date the manifest to certify to the information as 

amended. The facility must retain the amended manifest for at least three years from the date of 

amendment, and must within 30 days, send a copy of the amended manifest to the delivering 

transporter and to the generator. 

Data Items 

 Instructions provided by the generator. 

 Original manifest. 

 New manifest. 

 Shipping paper. 

Respondent Activities 

 Contact the generator to obtain the generator’s instructions for forwarding the waste 

to another facility that can manage the waste, as required by 40 CFR 264.72(d) or 
26

265.72(d). 

 Prepare a new manifest for rejected loads or container residues sent to the alternate 

designated facility or back to the generator: 

– Write the facility’s EPA ID, name, and address in the appropriate blocks of the 

new manifest (i.e. Items 1 and 5), as required by 40 CFR 264.72(e)(1) or (f)(1) or 

265.72(e)(1) or (f)(1). 

– Write the name of the alternate designated facility/initial generator and the 

facility’s/generator’s EPA ID number in the designated facility block (Item 8) of 

the new manifest, as required by 40 CFR 264.72(e)(2) or (f)(2) or 265.72(e)(2) or 

(f)(2). 

– Copy the manifest tracking number found in Item 4 of the old manifest to the 

Special Handling and Additional Information Block of the new manifest, and 

indicate that the shipment is a residue or rejected waste from the previous 

shipment, as required by 40 CFR 264.72(e)(3) or (f)(3) or 265.72(e)(3) or (f)(3). 

– Copy the manifest tracking number found in Item 4 of the new manifest to the 

manifest reference number line in the Discrepancy Block of the old manifest 

(Item 18a), as required by 40 CFR 264.72(e)(4) or (f)(4) or 265.72(e)(4) or (f)(4). 

– Write the USDOT description for the rejected load or the residue in the Item 9 

(USDOT Description) of the new manifest and write the container types, quantity, 

and volume(s) of waste, as required by 40 CFR 264.72(e)(5) or (f)(5) or 

265.72(e)(5) or (f)(5). 

– Sign the Generator’s/Offeror’s Certification to certify, as the offeror of the 

shipment, that the waste has been properly packaged, marked and labeled and is 

in proper condition, as required by 40 CFR 264.72(e)(6) or (f)(6) or 265.72(e)(6) 

or (f)(6). 

 Amend the facility’s copy of the manifest to indicate the rejected wastes or residues 

in the discrepancy space of the amended manifest, as required by 40 CFR 264.72(g) 

or 265.72(g). 

 Copy the manifest tracking number from Item 4 of the new manifest to the 

Discrepancy space of the amended manifest, as required by 40 CFR 264.72(g) or 

265.72(g). 

 Re-sign and date the manifest, as required by 40 CFR 264.72(g) or 265.72(g). 

 Retain the amended manifest for at least three years from the date of the amendment, 

as required by 40 CFR 264.72(g) or 265.72(g). 

 Within 30 days, send a copy of the amended manifest to the delivering transporter 

and to the generator, as required by 40 CFR 264.72(g) or 265.72(g). 

(b2) Rejection of Waste while the Transporter Remains Present at the Facility 

For container residues and full load rejections that are made while the transporter remains 

present at the facility, the facility may forward the shipment to the alternate facility or return the 

shipment to the generator using the original manifest, as specified in 40 CFR 264.72(e)(7) or 

(f)(7) or 40 CFR 265.72(e)(7) or (f)(7). 
27

Data Item 

 Original manifest. 

 Shipping paper. 

Respondent Activities 

 Contact the generator to obtain the generator’s instructions for forwarding the waste 

to another facility that can manage the waste, as required by 40 CFR 264.72(d) or 

265.72(d). 

 Complete Item 18a and 18b of the original manifest, as applicable, by supplying the 

information on the next destination facility or the generator in the Alternate Facility 

space. 

 Retain a copy of the manifest. 

 Give the remaining copies back to the transporter. 

(c) Unmanifested Waste Report: Completion and Submission 

Pursuant to 40 CFR 264.76 and 265.76, if the TSDF accepts a hazardous waste for treatment, 

storage, or disposal from any off-site source without an accompanying manifest or a shipping 

paper as described in 40 CFR 263.20(e)(2), and the waste is not excluded from the manifest 

requirement, the facility owner/operator must prepare and submit a letter to EPA. 

Data Item 

 An unmanifested waste report that includes: 

– The EPA ID number, name, and address of facility. 

– The date the facility received the waste. 

– The EPA ID number, name, and address of generator and transporter, if available. 

– A description and quantity of each unmanifested hazardous waste the facility 

received. 

– The method of treatment, storage, or disposal for each hazardous waste. 

– The certification signed by the owner/operator of the facility or his authorized 

representative. 

– A brief explanation of why the waste was unmanifested, if known. 

Respondent Activity 

 Prepare and submit to EPA a letter of the unmanifested waste within 15 days after 

receiving the waste. 

5. AGENCY ACTIVITIES, COLLECTION METHODOLOGY & INFORMATION 

MANAGEMENT 

The following subsections discuss how EPA will collect the information, what activities EPA 

will perform once the information has been received, and how EPA will manage the information 
28

it collects under the manifest system. The subsections also include a discussion of how the 

information collection requirements will affect small entities. 

5A. Agency Activities 

The Agency activities associated with the manifest requirements include the review of exception 

reports, discrepancy reports, and unmanifested waste reports. The Agency reviews these reports 

to identify potentially non-compliant or otherwise unresolved activities that warrant Agency 

attention. For example, upon receipt of an exception report, the Agency may conduct a followup investigation to assist the generator in locating the shipment. The Agency keeps these reports 

on file. In addition, EPA requires manifest form printers to register with EPA, as provided under 

40 CFR 262.21. The Agency will need to review, process, and keep records of the data 

submitted. 

5B. Collection Methodology & Management 

Under the registry, EPA will collect registrants’ initial applications under 40 CFR 262.21(b) 

through the regular mail, although some registrants may voluntarily choose to send them by 

certified mail. EPA will examine each application to ensure that the registrant takes appropriate 

steps to control its tracking numbers and print a quality manifest. EPA will then request form 

samples from the registrant through the mail. EPA will evaluate each registrant’s form samples 

to ensure they satisfy the print specifications at 40 CFR 262.21(f). EPA will then keep the forms 

on file for future reference. EPA will post the name, manifest tracking number suffix, and 

contact information of each approved registrant on its web site, so that the general public is 

aware of who the approved registrants are, what suffixes have been approved, and how to contact 

registrants for forms. 

In addition, EPA collects reports submitted by waste handlers under the manifest system (e.g., 

exception reports and discrepancy reports) through the regular mail, although some waste 

handlers may voluntarily choose to send them by certified mail. EPA reviews the reports to 

understand the situation at issue and take follow up action as needed. EPA keeps the files on 

record for future reference. 

5C. Small Entity Flexibility 

The current regulations require both large and small quantity generators of hazardous waste to 

use the manifest to track shipments of hazardous waste. However, the Agency has found that 

most small businesses do not generate hazardous waste either at all or in large enough quantities 

to make them subject to regulation and, therefore, are not affected by the manifest requirements. 

Generators of less than 100 kg/month (conditionally exempt small quantity generators) are 

exempted from manifest requirements. Also, EPA has exempted from the manifest requirements 

universal wastes (i.e., batteries, mercury thermostats, lamps, and pesticides, as specified), spent 

lead-acid batteries going for recycling, and used oil being recycled or burned for energy 

recovery. 

(1) Contractual Reclamation Agreements 
29

A small quantity generator (SQG) is exempt from the manifest requirements when his hazardous 

waste is reclaimed under a contractual agreement, and he complies with limited requirements, 

including recordkeeping of the contractual agreement, as required by 40 CFR 262.20(e)(2). 

(2) Exception Reports 

The exception report requirements, under 40 CFR 262.42, for SQGs are less stringent than those 

for large quantity generators (LQGs). A SQG is only required to submit to EPA a legible copy 

of the manifest with some indication he/she has not received confirmation of delivery and has 60 

days to fulfill this requirement. LQGs, on the other hand, are required to contact the transporter 

or facility owner/operator if he/she has not received a copy of the manifest within 35 days. In 

addition, if 45 days have passed and the LQG still has not received a signed copy of the manifest, 

he/she must submit a copy of the manifest as well as a cover letter explaining the generator’s 

efforts to locate the hazardous waste. Hence, the exception report requirements for SQGs are not 

as burdensome. 

5D. Collection Schedule 

(1) Registry Document Collection: Registrant Organizations 

Before printing the manifest for use or distribution, registrants must submit an initial application, 

three fully assembled manifests, and a description of the form samples to EPA. EPA will either 

approve the registrant to print the forms, or request modification to the application and/or 

samples before approval. In addition, registrants that would like to use a new tracking number 

suffix, change the printing specifications of their manifest, use a new printer, or typeset their 

manifest subsequent to EPA approval to print the manifest must submit additional documentation 

(e.g., proposed suffix, manifest samples, brief description of the new printer’s qualifications to 

print the manifest), as specified. 

Before an approved registrant can change its form in regard to paper type, paper weight, ink 

color of the instructions, or binding method, or before using a new printer, it must seek EPA 

approval by submitting new form samples and, if applicable, a description of the new printer. 

Note, however, that a registrant may request an exemption from the requirement to submit form 

samples if the Agency is persuaded that a separate review of the registrant’s forms would serve 

little purpose in informing an approval decision. Any approved registrant wanting to update any 

information provided in its application must revise the application and submit it to EPA, along 

with an indication or explanation of the update, as soon as practicable after the change occurs. 

Finally, an approved registrant must notify EPA by phone or email as soon as it becomes aware 

that it has duplicated manifest tracking numbers on forms that have been used or distributed. 

The registrant must also provide information on its printing activities, if requested by EPA. 
30

(2) Exception Reports Collection: Generators 

LQGs must submit exception reports to EPA within 45 days of the date the waste was accepted 

by the initial transporter, if he or she has not received a copy of the manifest signed by the 

TSDF. SQGs must submit an abbreviated version of an exception report to EPA within 60 days. 

(3) Manifests Returned to Generators: Designated TSDFs 

Designated TSDFs must return a signed and dated copy of the manifest to the generator within 

30 days after delivery of the waste. If a facility receives hazardous waste imported from a 

foreign source, the receiving facility must mail a copy of the manifest and documentation 

confirming EPA's consent to the import of hazardous waste to the following address within thirty 

(30) days of delivery: Office of Enforcement and Compliance Assurance, Office of Federal 

Activities, International Compliance Assurance Division (2254A), Environmental Protection 

Agency, 1200 Pennsylvania Avenue, NW., Washington, DC 20460. 

(4) Discrepancy and Unmanifested Waste Report Collection: Designated TSDFs 

Designated TSDFs must submit discrepancy reports and unmanifested waste reports to EPA 

within 15 days of delivery of the waste to the TSDF. 

6. ESTIMATE OF BURDEN HOURS & COST 

In this section, EPA estimates the total annual respondent and Agency hour and cost burden for 

all information collection requirements covered in this ICR. Exhibits 1 through 17 provide 

estimates of the annual respondent burden associated with these information collection 

requirements. Exhibit 18 presents the total aggregate annual cost burden to all respondents under 

the information collection requirements covered in this ICR. Exhibit 19 estimates Agency hour 

and cost burden. 

These exhibits estimate burden over the next three years for the paper-based manifest system. 

As discussed earlier, EPA is currently taking action to establish the national e-Manifest system, 

but unknown variables (e.g., funding contingencies for e-Manifest system development) could 

delay the actual deployment of the system. Therefore, until EPA announces that the e-Manifest 

system is available for use in a subsequent Federal Register document, all respondents under the 

information collection requirements covered in this ICR must continue to comply with the 

current paper-based manifest system and use the existing paper manifest forms for the off-site 

transportation of hazardous waste shipments. 

6A. Estimating the Respondent Universe 

Table 1 presents the annual number of respondents in this ICR. To develop these estimates, EPA 

queried RCRAInfo to identify facilities that, for purposes of the National Biennial Report for 
31

reporting year 2013, were considered to be: 1) shippers4; 2) receivers5; 3) managers6; and/or 4) 

generators7

. EPA developed a list of facilities in each group that included their EPA ID 

numbers. Then, EPA took the following additional steps: 

 

 For LQGs, EPA examined GM Form data to identify LQGs and non-LQGs (i.e., 

SQGs/CESQGs) based on their generated quantity of hazardous waste. EPA then 

compared the list of LQGs to the list of shippers and concluded that facilities whose 

EPA ID number appears on both lists are LQGs that shipped waste off-site. Finally, 

EPA determined that 3% of LQGs are federally owned/operated based on Site ID 

Forms and removed them from this analysis, resulting in the estimate shown in Table 

1. 

 

 For TSDFs acting as generators, EPA compared the list of managers (i.e., TSDFs) to 

the list of shippers and concluded that facilities whose EPA ID number appears on 

both lists are TSDFs that shipped waste off-site. EPA determined that 7% of TSDFs 

are federally owned/operated based on Site ID Forms and removed them from this 

analysis. Finally, EPA estimates that 25% of these TSDFs are commercial and 75% 

are captive, resulting in the estimates shown in Table 1. 

 For SQGs, EPA examined RCRAInfo data (e.g., notifications, Biennial Report data) 

to identify SQGs based on reported generator status and/or generated/shipped 

quantity of hazardous waste. EPA then compared the list of SQGs to the list of 

shippers and concluded that facilities whose EPA ID number appears on both lists are 

SQGs that shipped waste off-site. Finally, EPA determined that 3% of SQG shippers 

are federally owned/operated and removed them from this analysis, resulting in this 

ICR’s estimate of SQGs.8

 Finally, EPA estimates that 18% of SQGs operate pursuant 

to a reclamation agreement under 40 CFR 262.20(e) and are exempt from the 

requirement for a manifest. The remaining 82% do not operate under an agreement 

and are subject to the manifest requirements. This resulted in the estimates shown in 

Table 1. 

 For transporters, EPA referred to census data of the U.S. Department of Commerce, 

U.S. Census Bureau under NAICS Code 562112 (Hazardous Waste Collection), all 

establishments. EPA determined that 7% are federally owned/operated and removed 

them from this analysis, resulting in the estimate shown in Table 1. 

 For receivers (i.e., designated TSDFs), EPA referred to the number of facilities 

identified as “receivers” in the National Biennial Report for reporting year 2013. ICF 

determined that 6% of managers are federally owned/operated based on Site ID 

 

4

 The term “shipper” includes all sites that shipped RCRA hazardous waste off-site (e.g., LQGs, SQGs). 5

 The term “receiver” includes all sites that received RCRA hazardous waste from off-site. 6 The term “manager” includes sites that: (1) generated and managed RCRA hazardous waste at their site or (2) 

received RCRA hazardous waste from off-site for management. 7

 The term “generator” includes sites that: (1) generated RCRA hazardous waste at their sites or (2) served as the 

generator of record for hazardous wastes imported into the U.S. 8

 The SQG estimate in the table is preliminary. EPA is still refining the methodology and estimate. 
32

Forms and removed them from this analysis, resulting in the estimate shown in Table 

1. 

 

Table 1 

Annual Number of Respondents in ICR 

Type of Respondent Annual Number of 

Respondents 

Generators 

 LQGs 18,001 

 Commercial TSDFsa 234 

 Captive TSDFsa 703 

 SQGs (without reclamation agreements)b 52,496 

 SQGs (with reclamation agreements)b 11,524 

Total (Generators) 82,958 

Transporters 471 

Designated TSDFs 394 aIn general, TSDFs qualify as either LQGs or SQGs. However, EPA has found that TSDFs acting as generators often 

face burdens that are different from generators that are not TSDFs. Therefore, EPA has broken them out separately for 

purposes of examining burden in this analysis. 

b EPA’s estimate of SQGs is preliminary, as it is still refining the methodology and estimate. SQGs shipping under a 

reclamation agreement pursuant to 40 CFR 262.20(e) are not subject to the requirement for a manifest.

Table 2 presents the average number of manifests that each type of generator will offer into 

transportation. These averages are taken from the currently approved ICR. The table also shows 

the total annual number of manifests completed by all generators. In total, EPA estimates that 

generators will prepare and offer 1.41 million manifests into transportation on average annually. 

Table 2 

Annual Number of Manifests Prepared by Generators 

Type of Generator Number of 

Generators 

Average Annual 

Number of 

Manifests 

Completed per 

Generator 

Total Annual 

Number of 

Manifests 

Completed 

LQGs 18,001 46 828,046 

Commercial TSDFs 234 347 81,198 

Captive TSDFs 703 36 25,308 

SQGs (operating without reclamation 

agreements) 52,496 9 472,464 

Total 71,434 20a 1,407,016 a

 This number was calculated by dividing the total annual number of manifests by the total number of generators. It is presented 

for illustrative purposes only. It does not appear in the exhibits. 
33

6B. Estimating Respondent Costs 

Following is a discussion of respondent labor, capital and operation and maintenance (O&M) 

costs used in Exhibits 1 through 18. 

 

Labor Costs

EPA estimates an average hourly respondent labor cost of $ $96.98 for legal staff, $ $81.73 for 

managerial staff, $40.44 for technical staff, and $22.40 for clerical staff. To derive these hourly 

estimates, EPA referred to the May 2014 National Occupational Employment and Wage 

Estimates published by the U.S. Bureau of Labor Statistics.9

 This publication summarizes the 

unloaded (base) hourly rate for major occupational groups.10 EPA then applied a multiplier of 

1.4845 to derive loaded hourly rates (including fringe and overhead).11 Finally, EPA updated the 

loaded hourly rates to December 2014 levels using Employment Cost Indexes developed by the 

U.S. Bureau of Labor Statistics.12

Capital Costs

Capital costs usually include any produced physical good needed to provide the needed 

information, such as machinery, computers, and other equipment. For this ICR, capital costs 

include file cabinet costs. As shown in Exhibit 18, EPA estimates the total average annual 

capital cost to all hazardous waste handlers under the manifest system, collectively, to be 

$340,622. EPA took the following steps to derive the capital costs associated with the purchase 

of file cabinets: 

1. Estimate the total annual volume of paper manifests required to be retained by all 

waste handlers. Under the manifest system, generators, transporters, and 

designated TSDFs must keep copies of manifests and other manifest-related 

documents for a period of three years. Thus, at any given time during the 

effective period of this ICR, the hazardous waste industry is keeping paper copies 

of three years’ worth of manifest-related documents. In total, EPA estimates that 

waste handlers (i.e., generators, transporters, and designated TSDFs) will need to 

keep copies of 17,237,443 manifests and reports annually. 

 

9

 U.S. Bureau of Labor Statistics (BLS), Occupational Employment Statistics (OES), May 2014 National 

Occupational Employment and Wage Estimates (averages across all NAICS codes). Available online 

at:http://www.bls.gov/oes/current/oes_nat.htm, last accessed on April 20, 2015. Mean Hourly Wage. 10 For purposes of this analysis, the following occupational groups were used: Legal staff, SOC 23-1011 Lawyers; 

managerial staff, SOC 11-0000 Management Occupations; technical staff, SOC 17-3026 Industrial Engineering 

Technicians; and clerical staff, SOC 43-9061 Office Clerks, General. 11 Office of Management and Budget (OMB). Figure C1, OMB Circular A-76: Performance of Commercial 

Activities, May 29, 2003. Available online at: 

http://www.whitehouse.gov/omb/circulars/a076/a76_incl_tech_correction.html, last accessed on April 20, 2015. 12 Bureau of Labor Statistics, “Table 4. Employment Cost Index for total compensation, for civilian workers, by 

occupation and industry, Continuous occupational and industry series (not seasonally adjusted),” Employment Cost 

Index - Historical Listing, Volume V; January 2015. Available online at: http://www.bls.gov/web/eci/ecicois.pdf, 

last accessed on April 20, 2015. Civilian Workers, All Workers. 
34

2. Ascertain the number of standard-size file cabinets that would provide the needed 

capacity and estimate aggregate cost to waste handlers. EPA estimates that a 

standard-size, five-drawer, lateral file cabinet holds approximately 16,000 

documents. Thus, for storing 17,237,443 paper manifests and reports, waste 

handlers would need 1,077 file cabinets (i.e., 17,237,443/16,000) each year. 

These 1,077 file cabinets represent the total capacity needed by the industry, 

collectively, to store all of its paper manifests and reports. EPA estimates that the 

cost of one file cabinet is $829.9913 and for all 1,077 file cabinets is $893,899. 

3. Annualize the aggregate cost of standard-size file cabinets using a net present 

value formula. EPA used the following present value formula to annualize the 

cost of file cabinets over the three-year effective life of this ICR: 

Annualized Net Present Value = $893,899 x [1/(∑1/(1+k)t

)] 

 where k = discount rate of 7 percent; 

t = life of equipment (3 years).14

In total, EPA estimates that the hazardous waste industry will need to pay an annual cost 

of $340,622 for the 1,077 file cabinets. 

Operation and Maintenance (O&M) Costs

O&M costs are those costs associated with a paperwork requirement incurred continually over 

the life of the ICR. They are defined by the Paperwork Reduction Act of 1995 as “the recurring 

dollar amount of costs associated with O&M or purchasing services.” For this ICR, O&M costs 

include: 

 Printing cost for sample manifests: EPA estimates that respondents will incur a cost 

of $641 for each set of manifest form samples. These respondents are expected to 

contract with a printing company. Hence, the fee of $641 is considered a lump-sum 

cost. This O&M cost was obtained from the previously approved ICR (i.e., EPA ICR 

Number 0801.18, dated January 2012), and updated to 2015 levels using Consumer 

Price Indexes developed by the Bureau of Labor Statistics.15

 Purchase blank paper manifest forms from EPA-registered printer: EPA estimates 

that respondents will incur a cost of $0.42 for each blank paper manifest and $0.42 

for each blank manifest continuation sheet they purchase from an EPA-registered 

printer 16, 17

 

13 Standard-size, five-drawer, lateral file cabinet cost based on current market price, as of April 20, 2015. 14 Based on an OMB-approved discount rate of seven percent (OMB Circular A-94) and a required three-year 

record retention period for the manifest. 

15 Bureau of Labor Statistics, Historical Consumer Price Index for All Urban Consumers (CPI-U): U. S. city 

average, all items. Available online at: http://www.bls.gov/cpi/cpid1503.pdf, last accessed on April 20, 2015. 16 Uniform manifest form cost based on current market price, as of April 20, 2015. 17 Continuation sheet cost based on current market price, as of April 20, 2015. 
35

 Mailing costs: EPA estimates that respondents will incur a cost of $0.52 to mail a 

one-ounce package ($0.49 for postage and $0.03 for standard-size envelope)18, 19 EPA 

also estimates that respondents will incur a cost of $5.26 for mailing a larger package 

(i.e., a five-ounce package) by certified mail ($1.82 for postage, $3.30 for the 

certified-mail fee, and $0.14 for a catalog envelope).20, 21, 22 

 Photocopying costs: EPA estimates that respondents will incur a cost of $0.10 for 

each photocopy they make. 

 Long distance telephone call costs: EPA estimates that respondents will incur a cost 

of $2.00 for each long distance telephone call they make. 

6C. Estimating Agency Hour and Cost Burden 

EPA estimates the Agency hour and cost burden associated with the information collection 

requirements covered in this ICR in Exhibit 19. 

Labor Costs

As shown in the exhibits, EPA estimates an average hourly labor cost of $88.30 for legal staff 

(GS-15, Step 5), $77.92 for managerial staff (GS-15, Step 1), $56.05 for technical staff (GS-13, 

Step 1), and $23.92 for clerical staff (GS-06, Step 1). To derive these hourly estimates, EPA 

referred to the 2015 General Schedule (Base) for hourly rates.23 This publication summarizes 

the unloaded (base) hourly rate for various labor categories in the Federal Government. EPA 

then applied the standard government overhead factor of 1.6 to the unloaded rate to derive loaded 

hourly rates. 

Capital Costs

EPA anticipates that the Agency will not incur any significant capital costs under the current 

manifest system. 

 

18 U.S. Postal Service, “First-Class Mail - Retail.” Available online at: https://www.usps.com/business/first-classmail-for-business.htm?, last accessed on April 20, 2015. 19 Standard-size envelope cost based on current market price, as of April 20, 2015 (i.e., box of 500 standard business 

gummed envelopes at $15.79). 

20 U.S. Postal Service, “First-Class Mail - Retail.” Available online at: https://www.usps.com/business/first-classmail-for-business.htm?, last accessed on April 20, 2015. 21 U.S. Postal Service, “Domestic Insurance &Extra Services.” Available online at: 

https://www.usps.com/business/add-extra-services.htm?, last accessed on April 20, 2015. 22 Catalog envelope cost based on current market price, as of April 20, 2015 (i.e., box of 250 brown kraft catalog 

envelopes (9" x 12") at $35.39). 

23 U.S. Office of Personnel Management, “Salary Table 2015-GS, Incorporating the 1% General Schedule Increase 

Effective January 2015,” Hourly Rate. Available online at: http://www.opm.gov/policy-data-oversight/payleave/salaries-wages/salary-tables/pdf/2015/GS_h.pdf, last accessed on April 20, 2015. 
36

Operation and Maintenance Costs

For this ICR, EPA O&M costs include mailing costs associated with manifest registry activities. 

EPA estimates that the Agency will incur a cost of $0.52 to mail a one-ounce package ($0.49 for 

postage and $0.03 for standard-size envelope).24, 25 EPA also estimates that the Agency will 

incur a cost of $5.26 for mailing a larger package (i.e., a five-ounce package) by certified mail 

($1.82 for postage, $3.30 for the certified-mail fee, and $0.14 for a catalog envelope).26, 27, 28 

EPA O&M costs are shown in Exhibit 23 for all applicable activities. 

6D. Estimating Respondent Hours and Costs 

Refer to Section 6A of this document for many of the assumptions reflected in the exhibits. 

(a) Registrant Organization Requirements 

(a1) Reading the Regulations

Exhibit 1 presents the total annual hour and cost burden to registrant organizations in reading the 

manifest regulations at 40 CFR 262.21. EPA expects that on average, one registrant organization 

will read 40 CFR 262.21 regulations each year. 

(a2) Applying to the Registry

EPA estimates that each year, one entity will register with EPA to print its own forms. 

(a3) Updating General Information in the Approved Application

EPA estimates that, each year, three registrant organizations will revise and submit their 

approved application to EPA, along with an indication or explanation of the update, under 40 

CFR 262.21(h)(1). 

 

24 U.S. Postal Service, “First-Class Mail - Retail.” Available online at: https://www.usps.com/business/first-classmail-for-business.htm?, last accessed on April 20, 2015. 25 Standard-size envelope cost based on current market price, as of April 20, 2015 (i.e., box of 500 standard 

business gummed envelopes at $15.79). 

26 U.S. Postal Service, “First-Class Mail - Retail.” Available online at: https://www.usps.com/business/first-classmail-for-business.htm?, last accessed on April 20, 2015. 27 U.S. Postal Service, “Domestic Insurance &Extra Services.” Available online at: 

https://www.usps.com/business/add-extra-services.htm?, last accessed on April 20, 2015. 28 Catalog envelope cost based on current market price, as of April 20, 2015 (i.e., box of 250 brown kraft catalog 

envelopes (9" x 12") at $35.39). 
37

(a4) Requesting Approval for a New Tracking Number Suffix

EPA estimates that no approved registrant organization will request a new tracking number 

suffix during the 3-year period covered by this ICR. Because each manifest tracking number 

consists of the three-letter suffix and nine digits, each registrant will be able to generate more 

than 999 million forms using its original suffix. EPA does not expect a registrant to request a 

new suffix for many years. 

(a5) Requesting Approval for Changes to Printing Specifications or Use of a New 

Printer 

EPA estimates that one registrant organization annually will request approval for changes to its 

form or for the use of a new printer under 40 CFR 262.21(e). 

(a6) Typesetting the Manifest Form Subsequent to its Approval

EPA estimates that no registrant organization will typeset its manifest form, instead of using the 

electronic file of the forms provided by EPA, during the 3-year period covered by this ICR. 

Upon approval of a registrant’s application under 40 CFR 262.21(c), EPA will provide it with an 

electronic file of the manifest, continuation sheet, and instructions and ask it to use these files to 

develop the forms. In its consultations, EPA found that printers intend to share these files among 

their printing establishments so that none will need to typeset the form. Typesetting the form 

would be unappealing to registrants because of the level of effort required in comparison with 

using the electronic files. 

(a7) Requesting an Exemption

EPA estimates that no registrant organizations will submit a request for an exemption under 40 

CFR 262.21(j). EPA expects each registrant to be forward looking when originally registering 

under 40 CFR 262.21(b) through (e), and carefully select the appropriate paper type, paper 

weight, and other aspects of the form. 

(a8) Notifying EPA of a Printing Specification Violation

EPA estimates that one registrant organization will notify EPA that it has duplicated tracking 

numbers on forms used or distributed to other parties. Registrants must print their forms 

according to their approved applications, which will lay out procedures for tightly controlling 

their tracking numbers and ensuring that each manifest has a unique number. 

(a9) Revising the Approved Manifest if Requested by EPA

EPA estimates that no registrant organization will need to submit revised manifest form samples, 

per EPA’s request, during the 3-year period covered by this ICR. EPA will carefully review 

each registrant’s forms under 40 CFR 262.21(e) to determine if they satisfy the requirements of 

40 CFR 262.21(f). EPA does not expect to identify problems in forms that have been approved. 
EXHIBIT 1ESTIMATED ANNUAL HOUR AND COST BURDEN FOR REGISTRANT ORGANIZATIONS a

 Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numb

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Registr

Read the regulations 0.00 0.25 1.00 0.00 1.25 $60.87 $0.00 Prepare and submit initial application 0.00 0.25 1.00 0.10 1.35 $63.11 $5.26 Submit revised initial application to EPA, if requested 0.00 0.10 0.50 0.10 0.70 $30.63 $5.26 Submit three fully assembled manifests and, if needed, continuation sheets and a description of the form samples 0.00 0.10 0.17 0.10 0.37 $17.29 $646.26 Submit revised form samples based on EPA comment on the initial samples, if requested 0.00 0.10 0.17 0.10 0.37 $17.29 $646.26 Revise and submit the application to EPA, along with an indication or explanation of the update 0.00 0.10 0.17 0.10 0.37 $17.29 $0.52 Respond to the Agency’s concerns, if applicable 0.00 0.10 0.17 0.00 0.27 $15.05 $0.00 Submit a proposed tracking number suffix, along with the reason for requesting it 0.00 0.10 0.17 0.10 0.37 $17.29 $0.52 Submit three samples of the manifest form and/or continuation sheet and, if applicable, a brief description of the qualifications of the new printer 0.00 0.10 0.17 0.10 0.37 $17.29 $646.26 Submit revised manifest form and/or continuation sheet samples to EPA, if requested 0.00 0.10 0.17 0.10 0.37 $17.29 $646.26 Submit three samples of the manifest or continuation sheet to the registry for approval 0.00 0.00 0.17 0.10 0.27 $9.11 $646.26 Submit documentation to EPA indicating why an exemption is warranted 0.00 0.10 0.17 0.10 0.37 $17.29 $0.52 Notify EPA of duplicated manifest tracking numbers 0.00 0.00 0.25 0.00 0.25 $10.11 $2.00 Submit revised manifest form samples to EPA, if requested 0.00 0.10 0.17 0.10 0.37 $17.29 $646.26 Submit information if requested by EPA 0.00 0.25 0.50 0.00 0.75 $40.65 $0.52 TOTAL 0.00 varies varies varies varies varies varies 

a Exhibit contains rounding error.

Typesetting the Manifest Form Subsequent to its ApprovalResponding to Suspension and Revocation ProceduresRevising the Approved Manifest if Requested by EPARequesting an ExemptionNotifying EPA of a Printing Specification ViolationRequesting Approval for a New Tracking Number SuffixRequesting Approval for Changes to Printing Specifications or Use of a New Printer

Hours per Generator

Applying to the RegistryRead the regulationsUpdating General Information in the Approved Application
39

(a10) Responding to Suspension and Revocation Procedures

EPA does not expect to conduct suspension or revocation procedures during the 3-year period 

covered by this ICR. The registration process under 40 CFR 262.21(b) through (e) will ensure 

that each approved registrant is capable of tightly controlling its tracking numbers and printing 

forms consistent with the approved samples and the print specifications. Therefore, EPA 

anticipates it will rarely invoke its suspension and revocation procedures. 

(b) Generator Requirements 

(b1) Reading the Regulations

Exhibit 2 presents the total annual hour and cost burden to hazardous waste generators in reading 

the manifest regulations at 40 CFR Part 262. EPA expects that each generator will read the 40 

CFR Part 262 regulations each year. 

(b2) Manifest Completion

Exhibits 3 and 4 present the total annual hour and cost burden for generators to complete their 

manifests. The exhibits reflect the fact that designated TSDFs often provide assistance to their 

generator customers in preparing manifests for shipments to their facility. For purposes of 

analysis, this ICR assumes that a percentage of LQGs and SQGs rely on the designated TSDFs’ 

assistance in manifest preparation, while the remaining LQGs and SQGs, as well as all TSDFs 

acting as generators, prepare their manifests themselves, as follows: 

 Completing the Manifest without the Assistance of Designated TSDF: Based on 

consultations with hazardous waste generators and the States, EPA estimates that 

about 58% of LQG manifests and 20% of SQG manifests accompanying hazardous 

waste shipments are prepared without the assistance of the designated TSDF. This is 

reflected in Exhibit 3. In addition, EPA estimates that about 5% of manifests include 

continuation sheets. 

 Completing the Manifest With the Assistance of Designated TSDF: As discussed, 

EPA recognizes that many LQGs and SQGs rely on the assistance of the designated 

TSDF to complete the manifest form. Because the designated TSDF normally fills 

out most of the manifest form for the generator, the collaborative effort significantly 

reduces the burden on generators. Based on its consultations, EPA estimates that 

about 42% of manifests from LQGs and 80% of manifests from SQGs are jointly 

completed with the designated TSDF. This is reflected in Exhibit 4. [Note: Refer to 

Exhibit 14 for the hour and cost burden for designated TSDFs to assist LQGs and 

SQGs in completing their manifests.] 
EXHIBIT 2ESTIMATED ANNUAL HOUR AND COST BURDEN FOR GENERATORS aREADING THE REGULATIONS

 Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numb

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Genera

LQGs 0.00 0.25 1.00 0.00 1.25 $60.87 $0.00 TSDFs 0.00 0.25 1.00 0.00 1.25 $60.87 $0.00 SQGs 0.00 0.25 1.00 0.00 1.25 $60.87 $0.00 TOTAL (LQGs, TSDFs, and SQGs) 0.00 0.25 1.00 0.00 1.25 $60.87 $0.00 

a Exhibit contains rounding error.

Hours per Generator

Read the regulations

EXHIBIT 3ESTIMATED ANNUAL HOUR AND COST BURDEN FOR GENERATORS aCOMPLETING THE MANIFEST (WITHOUT ASSISTANCE OF DESIGNATED TSDFs)

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numbe

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Manife

Complete the manifest 0.00 0.00 0.40 0.10 0.50 $18.42 $0.42 4Complete the continuation sheet 0.00 0.00 0.19 0.04 0.23 $8.58 $0.42 Complete the manifest 0.00 0.00 0.43 0.10 0.53 $19.63 $0.42 Complete the continuation sheet 0.00 0.00 0.18 0.04 0.22 $8.18 $0.42 Complete the manifest 0.00 0.00 0.43 0.10 0.53 $19.63 $0.42 Complete the continuation sheet 0.00 0.00 0.18 0.05 0.23 $8.40 $0.42 Complete the manifest 0.00 0.00 0.40 0.08 0.48 $17.97 $0.42 Complete the continuation sheet 0.00 0.00 0.18 0.03 0.21 $7.95 $0.42 TOTAL (LQGs, TSDFs, and SQGs) b 0.00 0.00 varies varies varies varies $0.00 6

a Exhibit contains rounding error.

b Total reflect the number of manifests, i.e. the number of continuation sheets is not reflected.

Manifest completion: Captive TSDFs who are also generators

Hours per Generator

Manifest completion: LQGsManifest completion: Commercial TSDFs who are also generatorsManifest completion: SQGs
EXHIBIT 4ESTIMATED ANNUAL HOUR AND COST BURDEN FOR GENERATORS aCOMPLETING THE MANIFEST (WITH ASSISTANCE OF DESIGNATED TSDFs)

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numbe

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Manife

Complete the manifest 0.00 0.00 0.02 0.01 0.03 $1.03 $0.00 3Complete the manifest 0.00 0.00 0.02 0.01 0.03 $1.03 $0.00 3TOTAL (LQGs and SQGs) 0.00 0.00 0.02 0.01 0.03 $1.03 $0.00 7

a Exhibit contains rounding error.

Manifest completion: LQGs

Hours per Generator

Manifest completion: SQGs

EXHIBIT 5ESTIMATED ANNUAL HOUR AND COST BURDEN FOR GENERATORS aCOMPLIANCE WITH STATE PROGRAM REQUIREMENTS

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numbe

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Phone 

Contact the consignment/generator State if needed and submit any copies of the manifest to these States, as applicable 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 Contact the consignment/generator State if needed and submit any copies of the manifest to these States, as applicable 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 Contact the consignment/generator State if needed and submit any copies of the manifest to these States, as applicable 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 Contact the consignment/generator State if needed and submit any copies of the manifest to these States, as applicable 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 TOTAL (LQGs, TSDFs, and SQGs) 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 2

a Exhibit contains rounding error.

Compliance with State program requirements: SQGs

Hours per Generator

Compliance with State program requirements: TSDFs who are also generatorsCommercial TSDFsCaptive TSDFsCompliance with State program requirements: LQGs
EXHIBIT 6ESTIMATED ANNUAL HOUR AND COST BURDEN FOR GENERATORS aTRANSMITTING THE MANIFEST

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numbe

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Manife

Sign the manifest certification and obtain the signature of the initial transporter and date of acceptance on the manifest 0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 8Keep a copy of the manifest and give the remaining copies to the initial transporter 0.00 0.00 0.00 0.10 0.10 $2.24 $0.00 8Keep a copy of the manifest returned from the designated facility 0.00 0.00 0.00 0.10 0.10 $2.24 $0.00 8For shipments solely by water, send three copies of the manifest, dated and signed, to the designated facility or the last water transporter to handle the waste in the U.S.

0.00 0.00 0.00 0.16 0.16 $3.58 $0.52 

For shipments by rail originating at the site of generation, send at least three copies of the manifest to the next non-rail transporter, the designated facility, or the last rail transporter to handle the waste in the U.S.

0.00 0.00 0.00 0.16 0.16 $3.58 $0.52 

Provide the transporter with an EPA Acknowledgment of Consent and an additional copy of the manifest or shipping papers for delivery to the U.S. Customs official at the point the hazardous waste exits the U.S.

0.00 0.00 0.00 0.25 0.25 $5.60 $0.10 

Subtotal (for LQGs) 0.00 0.00 varies varies varies varies varies 

a Exhibit contains rounding error.

Exports 

Hours per Generator

Manifest transmittal and recordkeeping: LQGs Manifest

EXHIBIT 6 (CONTINUED)ESTIMATED ANNUAL HOUR AND COST BURDEN FOR GENERATORS aTRANSMITTING THE MANIFEST

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numbe

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Manife

ManifestSign the manifest certification and obtain the signature of the initial transporter and date of acceptance on the manifest 0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 Keep a copy of the manifest and give the remaining copies to the initial transporter 0.00 0.00 0.00 0.10 0.10 $2.24 $0.00 

Keep a copy of the manifest returned from the designated facility 0.00 0.00 0.00 0.10 0.10 $2.24 $0.00 For shipments solely by water, send three copies of the manifest, dated and signed, to the designated facility or the last water transporter to handle the waste in the U.S.(Domestic and Exports)

0.00 0.00 0.00 0.16 0.16 $3.58 $0.52 

For shipments by rail originating at the site of generation, send at least three copies of the manifest to the next non-rail transporter, the designated facility, or the last rail transporter to handle the waste in the U.S. (Domestic and Exports)

0.00 0.00 0.00 0.16 0.16 $3.58 $0.52 

Provide the transporter with an EPA Acknowledgment of Consent and an additional copy of the manifest or shipping papers for delivery to the U.S. Customs official at the point the hazardous waste exits the U.S.

0.00 0.00 0.00 0.25 0.25 $5.60 $0.10 

Subtotal (for Commercial TSDFs) 0.00 0.00 varies varies varies varies varies 

a Exhibit contains rounding error.

Exports 

Hours per Generator

Manifest transmittal and recordkeeping: Commercial TSDFs
EXHIBIT 6 (CONTINUED)ESTIMATED ANNUAL HOUR AND COST BURDEN FOR GENERATORS aTRANSMITTING THE MANIFEST

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numbe

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Manife

ManifestSign the manifest certification and obtain the signature of the initial transporter and date of acceptance on the manifest 0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 Keep a copy of the manifest and give the remaining copies to the initial transporter 0.00 0.00 0.00 0.10 0.10 $2.24 $0.00 Keep a copy of the manifest returned from the designated facility 0.00 0.00 0.00 0.10 0.10 $2.24 $0.00 For shipments solely by water, send three copies of the manifest, dated and signed, to the designated facility or the last water transporter to handle the waste in the U.S.(Domestic and Exports)

0.00 0.00 0.00 0.16 0.16 $3.58 $0.52 

For shipments by rail originating at the site of generation, send at least three copies of the manifest to the next non-rail transporter, the designated facility, or the last rail transporter to handle the waste in the U.S. (Domestic and Exports)

0.00 0.00 0.00 0.16 0.16 $3.58 $0.52 

Provide the transporter with an EPA Acknowledgment of Consent and an additional copy of the manifest or shipping papers for delivery to the U.S. Customs official at the point the hazardous waste exits the U.S.

0.00 0.00 0.00 0.25 0.25 $5.60 $0.10 

Subtotal (for Captive TSDFs) 0.00 0.00 varies varies varies varies varies 

a Exhibit contains rounding error.

Hours per Generator

Manifest transmittal and recordkeeping: Captive TSDFsExports 

EXHIBIT 6 (CONTINUED)ESTIMATED ANNUAL HOUR AND COST BURDEN FOR GENERATORS aTRANSMITTING THE MANIFEST

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numbe

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Manife

ManifestSign the manifest certification and obtain the signature of the initial transporter and date of acceptance on the manifest 0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 4Keep a copy of the manifest and give the remaining copies to the initial transporter 0.00 0.00 0.00 0.10 0.10 $2.24 $0.00 4Keep a copy of the manifest returned from the designated facility 0.00 0.00 0.00 0.10 0.10 $2.24 $0.00 4For shipments solely by water, send three copies of the manifest, dated and signed, to the designated facility or the last water transporter to handle the waste in the U.S.(Domestic and Exports)

0.00 0.00 0.00 0.16 0.16 $3.58 $0.52 

For shipments by rail originating at the site of generation, send at least three copies of the manifest to the next non-rail transporter, the designated facility, or the last rail transporter to handle the waste in the U.S. (Domestic and Exports)

0.00 0.00 0.00 0.16 0.16 $3.58 $0.52 

Provide the transporter with an EPA Acknowledgment of Consent and an additional copy of the manifest or shipping papers for delivery to the U.S. Customs official at the point the hazardous waste exits the U.S.

0.00 0.00 0.00 0.25 0.25 $5.60 $0.10 

Retain a copy of each reclamation agreement 0.00 0.00 0.00 0.10 0.10 $2.24 $0.00 Subtotal (for SQGs) 0.00 0.00 varies varies varies varies varies TOTAL (LQGs, TSDFs, and SQGs) 0.00 0.00 varies varies varies varies varies 

a Exhibit contains rounding error.

Reclamation Agreements

Hours per Generator

Manifest transmittal and recordkeeping: SQGsExports
EXHIBIT 7ESTIMATED ANNUAL HOUR AND COST BURDEN FOR GENERATORS aUNDELIVERABLE SHIPMENTS

 Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numbe

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Manife

Designate another facility or instruct the transporter to return the waste 0.00 0.00 0.08 0.00 0.08 $3.24 $0.00 Designate another facility or instruct the transporter to return the waste 0.00 0.00 0.08 0.00 0.08 $3.24 $0.00 Designate another facility or instruct the transporter to return the waste 0.00 0.00 0.08 0.00 0.08 $3.24 $0.00 Designate another facility or instruct the transporter to return the waste 0.00 0.00 0.08 0.00 0.08 $3.24 $0.00 TOTAL (LQGs, TSDFs, and SQGs) 0.00 0.00 0.08 0.00 0.08 $3.24 $0.00 

a Exhibit contains rounding error.

Undeliverable shipments: SQGsUndeliverable shipments: Captive TSDFs

Hours per Generator

Undeliverable shipments: Commercial TSDFsUndeliverable shipments: LQGs

EXHIBIT 8ESTIMATED ANNUAL HOUR AND COST BURDEN FOR GENERATORS aREJECTED WASTE AND CONTAINER RESIDUES

 Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numbe

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Manife

Sign Item 18c of the manifest, if the transporter returned the shipment using the original manifest 0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 Sign Item 20 of the manifest, if the transporter returned the shipment using a new manifest 0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 Provide the transporter a copy of the manifest 0.00 0.00 0.17 0.00 0.17 $6.87 $0.00 Within 30 days of delivery, send a copy to the designated TSDF that returned the shipment to the generator 0.00 0.00 0.00 0.15 0.15 $3.36 $0.52 Retain a copy 0.00 0.00 0.00 0.17 0.17 $3.81 $0.00 TOTAL 0.00 0.00 varies varies varies varies varies 

a Exhibit contains rounding error.

Rejected waste and container residues

Hours per Generator
EXHIBIT 9ESTIMATED ANNUAL HOUR AND COST BURDEN FOR GENERATORS aDEVELOPING EXCEPTION REPORTS

 Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numbe

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Repo

Prepare and submit a signed cover letter to EPA explaining the generator’s efforts to locate the hazardous waste and the results of those efforts, along with a legible copy of the manifest

0.00 0.50 0.50 0.10 1.10 $63.32 $0.62 

Keep a copy of each exception report 0.00 0.00 0.00 0.10 0.10 $2.24 $0.10 Prepare and submit a signed cover letter to EPA explaining the generator’s efforts to locate the hazardous waste and the results of those efforts, along with a legible copy of the manifest

0.00 0.50 0.50 0.10 1.10 $63.32 $0.62 

Keep a copy of each exception report 0.00 0.00 0.00 0.10 0.10 $2.24 $0.10 Prepare and submit a signed cover letter to EPA explaining the generator’s efforts to locate the hazardous waste and the results of those efforts, along with a legible copy of the manifest

0.00 0.50 0.50 0.10 1.10 $63.32 $0.62 

Keep a copy of each exception report 0.00 0.00 0.00 0.10 0.10 $2.24 $0.10 Submit a legible copy of the manifest with some indication that the waste has not been delivered 0.00 0.25 0.25 0.00 0.50 $30.54 $0.62 TOTAL (LQGs, TSDFs, and SQGs) 0.00 varies varies varies varies varies varies 

a Exhibit contains rounding error.

Exception report completion, submission, and recordkeeping: SQGsException report completion, submission, and recordkeeping: Commercial TSDFsException report completion, submission, and recordkeeping: LQGs

Hours per Generator

Exception report completion, submission, and recordkeeping: Captive TSDFs
46

(b3) Compliance with State Program Requirements

40 CFR 262.21(g)(2) provides that generators must determine whether they are required to 

comply with requirements specific to State hazardous waste manifest programs. As shown in 

Exhibit 5, EPA assumes that each generator must contact, on average, three State manifest 

programs each year. Because these activities are performed to learn about state-specific 

requirements and not the federal program, they are not burdened in this ICR.

 (b4) Manifest Transmittal and Recordkeeping

As shown in Exhibit 6, EPA estimates that LQGs, TSDFs acting as generators, and SQGs will 

send 3% of their manifests with water shipments and 6% with rail shipments. In addition, EPA 

estimates that 11,524 SQGs ship their hazardous waste off-site under a reclamation agreement, 

pursuant to 40 CFR 262.20. These SQGs are exempt from the requirement for a manifest but 

must keep a copy of the contractual agreement under which their hazardous waste is shipped to 

the recycling facility. 

(b5) Undeliverable Shipments

Based on consultations as shown in Exhibit 7, EPA estimates that roughly 0.10% of shipments 

cannot be delivered to the designated TSDF each year. Generators must provide instructions to 

the transporter on how to deal with these shipments, as required by 40 CFR 262.20(d) and 

262.54(g)(3). 

(b6) Rejected Waste and Container Residues

As shown in Exhibit 8, EPA estimates that, each year, a small percentage of shipments initiated 

by generators will be rejected by designated TSDFs and sent back to the generator. Upon receipt 

of the rejected shipments, generators must sign the manifest that accompanies the rejected load 

or residue. 

(b7) Exception Reports: Completion, Submission, and Recordkeeping

EPA estimates that, on average, LQGs, TSDFs acting as generators, and SQGs will need to 

develop an exception report under 40 CFR 262.42 for approximately 0.7% of the manifests sent 

off-site. This assumption is reflected in Exhibit 9. 

(c) Transporter Requirements 

 (c1) Reading the Regulations

As shown in Exhibit 10, there are reportedly 471 hazardous waste transporter companies subject 

to the RCRA manifest system. EPA expects that each company will read the manifest 

regulations once a year. 
EXHIBIT 10ESTIMATED ANNUAL HOUR AND COST BURDEN FOR TRANSPORTERS aREADING THE REGULATIONS

 Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numbe

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Transpo

Transporters 0.00 0.25 1.00 0.00 1.25 $60.87 $0.00 TOTAL 0.00 0.25 1.00 0.00 1.25 $60.87 $0.00 

a Exhibit contains rounding error.

Hours per Transporter

Read the regulations

EXHIBIT 11ESTIMATED ANNUAL HOUR AND COST BURDEN FOR TRANSPORTERS aCOMPLETING AND TRANSMITTING THE MANIFEST

 Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numbe

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Manife

Sign and date the manifest 0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 1,2Return a signed copy of the manifest to the generator 0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 1,2Ensure that the manifest (or other shipping paper) accompanies the waste to its destination 0.00 0.00 0.13 0.00 0.13 $5.26 $0.00 1,2Obtain the date of delivery and signature of that transporter or the owner/operator of the facility or alternate facility designated on the manifest 0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 1,2Retain a copy of the manifest 0.00 0.00 0.00 0.17 0.17 $3.81 $0.00 1,2Give remaining copies of the manifest to the accepting transporter or facility 0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 1,2

a Exhibit contains rounding error.

Manifest requirements for highway transporters

Hours per Transporter

Manifest completion, transmittal and recordkeeping: Transporters

EXHIBIT 11 (CONTINUED)ESTIMATED ANNUAL HOUR AND COST BURDEN FOR TRANSPORTERS aCOMPLETING AND TRANSMITTING THE MANIFEST

 Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numbe

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Manife

Obtain the date of delivery and signature of the initial water transporter on the manifest 0.00 0.00 0.00 0.01 0.01 $0.22 $0.00 Forward the manifest to the designated facility 0.00 0.00 0.00 0.16 0.16 $3.58 $0.52 Ensure that the shipping paper (and Acknowledgment of Consent, for exports) accompanies the waste to its destination 0.00 0.00 0.13 0.00 0.13 $5.26 $0.00 If the delivering (water) transporter, obtain the date of delivery and signature of the owner/operator of the designated facility on either the manifest or shipping paper 0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 If the initial water transporter, sign and date the manifest and return it to the delivering transporter so that the manifest can be forwarded to the designated facility owner/operator

0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 

Retain a copy of the manifest or shipping paper 0.00 0.00 0.00 0.17 0.17 $3.81 $0.00 

a Exhibit contains rounding error.

Manifest requirements for person delivering to initial water transporters

Hours per Transporter

Manifest completion, transmittal and recordkeeping: TransportersManifest requirements for water (bulk shipment) transporters
EXHIBIT 11 (CONTINUED)ESTIMATED ANNUAL HOUR AND COST BURDEN FOR TRANSPORTERS aCOMPLETING AND TRANSMITTING THE MANIFEST

 Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numbe

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Manife

When accepting waste from a non-rail transporter, sign and date the manifest and return or transmit a signed copy of the manifest to the non-rail transporter 0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 Forward at least three copies of the manifest to either the next non-rail transporter, the designated facility, or the last rail transporter designated to handle the waste in the U.S.

0.00 0.00 0.00 0.16 0.16 $3.58 $0.52 

Ensure a shipping paper containing all the information required on the manifest excluding the U.S. EPA ID number, generator certification, and signatures (and for exports an Acknowledgment of Consent) accompanies the waste

0.00 0.00 0.13 0.00 0.13 $5.26 $0.00 

When delivering hazardous waste to the designated facility or to the next non-rail transporter, obtain the signature and date of delivery of the facility or non-rail transporter on the manifest

0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 

Retain a copy of the manifest and/or rail shipping paper 0.00 0.00 0.00 0.17 0.17 $3.81 $0.00 Before accepting hazardous waste from a rail transporter, sign and date the manifest and provide a copy to the rail transporter 0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 

a Exhibit contains rounding error.

Hours per Transporter

Manifest completion, transmittal and recordkeeping: TransportersManifest requirements for rail transporters

EXHIBIT 11 (CONTINUED)ESTIMATED ANNUAL HOUR AND COST BURDEN FOR TRANSPORTERS aCOMPLETING AND TRANSMITTING THE MANIFEST

 Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numbe

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Manife

For imports and exports, sign and date the manifest in the International Shipments block to indicate the date that the shipment left the U.S., as required by section 263.20(g)(1)

0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 

For imports and exports, retain a copy of the manifest, as required by section 263.20(g)(2) 0.00 0.00 0.00 0.17 0.17 $3.81 $0.00 For imports, give copy of import manifest to TSDF receiving facility 0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 For exports, return a signed copy of the manifest to the generator, as required by section 263.20(g)(3) 0.00 0.00 0.00 0.01 0.01 $0.22 $0.00 For exports, give a copy of the manifest to a U.S. Customs official at the point of departure from the U.S., as required by section 263.20(g)(4) 0.00 0.00 0.01 0.00 0.01 $0.40 $0.10 For exports, ensure that copies of the manifest and EPA Acknowledgment of Consent accompanies the waste, as required by section 263.20(a) 0.00 0.00 0.13 0.00 0.13 $5.26 $0.00 Record the waste information on a log or shipping paper 0.00 0.25 0.75 0.00 1.00 $50.76 $0.00 Carry the record when transporting waste to the reclamation facility 0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 Retain the records 0.00 0.00 0.00 0.17 0.17 $3.81 $0.00 

a Exhibit contains rounding error.

Manifest completion, transmittal and recordkeeping: TransportersManifest requirements for transporters who transport waste pursuant to a reclamation agreement

Hours per Transporter

Manifest requirements for transporters who transport waste into and/or out of the U.S.
EXHIBIT 11 (CONTINUED)ESTIMATED ANNUAL HOUR AND COST BURDEN FOR TRANSPORTERS aCOMPLETING AND TRANSMITTING THE MANIFEST

 Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numbe

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Manife

Contact the generator for further directions and revise the manifest according to the generator’s instructions 0.00 0.00 0.08 0.00 0.08 $3.24 $2.00 For partially rejected loads made while the transporter is on site, obtain the amended manifest from the facility, keep a copy, and, if receiving the rejected waste, obtain the new manifest

0.00 0.00 0.10 0.00 0.10 $4.04 $0.00 

For fully rejected loads made or container residues identified while the transporter is on site, obtain the original manifest, as amended, from the facility 0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 TOTAL varies varies varies varies varies varies varies 

a Exhibit contains rounding error.

Hours per Transporter

Rejected waste and container residuesUndeliverable shipments

EXHIBIT 12ESTIMATED ANNUAL HOUR AND COST BURDEN FOR TRANSPORTERS aNOTIFYING OF DISCHARGE OF HAZARDOUS WASTE

 Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numbe

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Notifica

Notify local authorities 0.00 0.25 1.00 0.00 1.25 $60.87 $0.00 Notify NRC, or a predesignated OSC, of the discharge 0.00 0.25 1.00 0.00 1.25 $60.87 $0.00 TOTAL 0.00 varies 1.00 0.00 1.25 $60.87 $0.00 

a Exhibit contains rounding error.

Hours per Transporter

Notification of discharge of hazardous waste: Water (bulk shipment) TransportersNotification of discharge of hazardous waste: Transporters
50

(c2) Manifest Completion, Transmittal, and Recordkeeping

Exhibit 11 examines the manifesting hour and cost burden for transporters transporting domestic 

and international shipments of hazardous waste. EPA estimates that, of the manifests completed 

and transmitted each year for domestic and import shipments, approximately 91% will 

accompany highway shipments, 3% will accompany water shipments, and 6% will accompany 

rail shipments. In addition, Exhibit 11 shows the number of manifest accompanying export 

shipments, import shipments, undelivered shipments, and rejected shipments and container 

residues. 

 (c3) Notification of Discharge of Hazardous Waste

Based on the Statistical Abstract of the United States, EPA estimates that approximately 15,000 

accidents per year involve transporters of hazardous substances. EPA has used its best judgment 

to estimate that 5% of these accidents involve transporters of hazardous waste annually (i.e., 

hazardous waste is a subset of hazardous substances). These transporters will be required to 

notify local authorities of the discharge as required under 40 CFR 263.30. This is reflected in 

Exhibit 12. 

In addition, based on data from the National Response Center (NRC), EPA estimates that the 

NRC receives approximately 4,500 notifications of marine source incidents for discharges of oil 

or hazardous substances annually. NRC data also indicate that about 66% of these incidents 

involved oil discharges and 33% involved hazardous substances discharges. Of the discharges of 

hazardous substances, EPA estimates that 5% involve water transporters transporting hazardous 

waste. These transporters must notify NRC or EPA under 33 CFR Part 153. The purpose of 33 

CFR Part 153 is to prescribe regulations concerning notification to the US Coast Guard of the 

discharge of oil or hazardous substances as required by the Federal Water Pollution Control Act, 

as amended; the procedures for the removal of a discharge of oil; and the costs that may be 

imposed or reimbursed for the removal of a discharge of oil or hazardous substances. 

(d) Designated Treatment, Storage, and Disposal Facility Requirements 

(d1) Reading the Regulations

Based on EPA’s 2009 RCRA Hazardous Waste Biennial Report (BR) data, EPA estimates that 

394 designated TSDFs receive off-site shipments of hazardous waste each year. As shown in 

Exhibit 13, EPA expects that each facility will read the manifest regulations once a year. 

(d2) Completing the Manifest (assisting the generators)

Exhibit 14 presents EPA’s estimates that approximately 42% and 80% of manifests from LQGs 

and SQGs, respectively, are completed jointly with the designated TSDF. In addition, EPA 

estimates that 5% of these manifests include continuation sheets. 
EXHIBIT 13ESTIMATED ANNUAL HOUR AND COST BURDEN FOR DESIGNATED TREATMENT, STORAGE, AND DISPOSAL FACILITIES (TSDFs) aREADING THE REGULATIONS

 Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numbe

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent TSD

TSDFs 0.00 0.25 1.00 0.00 1.25 $60.87 $0.00 TOTAL 0.00 0.25 1.00 0.00 1.25 $60.87 $0.00 

a Exhibit contains rounding error.

Read the regulations

Hours per TSDF

EXHIBIT 14ESTIMATED ANNUAL HOUR AND COST BURDEN FOR DESIGNATED TREATMENT, STORAGE, AND DISPOSAL FACILITIES (TSDFs) aCOMPLETING THE MANIFEST (ASSISTING THE GENERATORS)

 Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numbe

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Manife

Complete the manifest 0.00 0.00 0.43 0.10 0.53 $19.63 $0.42 7Complete continuation sheets 0.00 0.00 0.18 0.04 0.22 $8.18 $0.42 TOTAL 0.00 0.00 varies varies varies varies $0.00 7

a Exhibit contains rounding error.

Hours per TSDF

Manifest completion: Designated TSDFs

EXHIBIT 15ESTIMATED ANNUAL HOUR AND COST BURDEN FOR DESIGNATED TREATMENT, STORAGE, AND DISPOSAL FACILITIES (TSDFs) aTRANSMITTING THE MANIFEST AND REPORTING TO EPA

Numbe

 Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Manife

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Respon

Enter the name of the person accepting the waste and sign and date each copy of the manifest (or shipping paper, if applicable) 0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 1,3Complete the management method code 0.00 0.00 0.02 0.00 0.02 $0.81 $0.00 1,3Note any discrepancies on each copy of the manifest (or shipping paper, if applicable) 0.00 0.00 0.08 0.00 0.08 $3.24 $0.00 3Immediately give the transporter at least one copy of the manifest (or shipping paper) 0.00 0.00 0.17 0.00 0.17 $6.87 $0.00 1,3Within 30 days of delivery, send a copy of the manifest (or shipping paper) to the generator (or to EPA-OECA for import manifests) 0.00 0.00 0.00 0.15 0.15 $3.36 $0.52 1,3Retain a copy of the manifest (or shipping paper) for at least three years from the delivery date (includes import manifests) 0.00 0.00 0.00 0.17 0.17 $3.81 $0.00 1,3Contact the consignment/generator State if needed and submit any copies of the manifest to these States, as applicable 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 Contact the consignment/generator State if needed and submit any copies of the manifest to these States, as applicable 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 Attempt to reconcile any discrepancies 0.00 0.00 0.08 0.00 0.08 $3.24 $2.00 3Prepare and submit a letter to EPA describing the discrepancy and attempts to reconcile it, along with a copy of the manifest or shipping paper at issue 0.00 0.10 0.17 0.10 0.37 $17.29 $0.62 TOTAL 0.00 varies varies varies varies varies varies 

a Exhibit contains rounding error.

Manifest completion, transmittal and recordkeeping: Designated TSDFs

Hours per TSDF

Commercial TSDFsCompliance with State program requirements: TSDFs who are also generatorsCaptive TSDFsDiscrepancy report completion and submission: Designated TSDFs
EXHIBIT 16ESTIMATED ANNUAL HOUR AND COST BURDEN FOR DESIGNATED TREATMENT, STORAGE, AND DISPOSAL FACILITIES (TSDFs) aREJECTED WASTE AND CONTAINER RESIDUES

Numbe

 Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Manife

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Respon

Enter the name of the person accepting the waste and sign and date each copy of the manifest (or shipping paper, if applicable) 0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 Complete the management method code 0.00 0.00 0.02 0.00 0.02 $0.81 $0.00 Immediately give the transporter at least one copy of the manifest (or shipping paper) 0.00 0.00 0.17 0.00 0.17 $6.87 $0.00 Within 30 days of delivery, send a copy of the manifest (or shipping paper) to the generator or EPA OECA (for imports) 0.00 0.00 0.00 0.16 0.16 $3.58 $0.52 Contact the generator to obtain the generator’s instructions for forwarding the waste to another facility that can manage the waste 0.00 0.00 0.08 0.00 0.08 $3.24 $2.00 Prepare a new manifest for rejected loads or container residues sent to the alternate designated facility or back to the generator 0.00 0.00 0.43 0.10 0.53 $19.63 $0.00 Amend the facility’s copy of the manifest to indicate the rejected wastes or residues in the discrepancy space of the amended manifest 0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 Copy the manifest tracking number from Item 4 of the new manifest to the Discrepancy space of the amended manifest 0.00 0.00 0.02 0.00 0.02 $0.81 $0.00 Re-sign and date the manifest 0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 Retain the amended manifest for at least three years from the date of the amendment 0.00 0.00 0.00 0.17 0.17 $3.81 $0.00 Within 30 days, send a copy of the amended manifest to the delivering transporter and to the generator 0.00 0.00 0.00 0.16 0.16 $3.58 $0.52 

a Exhibit contains rounding error.

Rejected waste and container residues

Hours per TSDF

Rejection of Waste after the Transporter Leaves the Facility

EXHIBIT 16 (CONTINUED)ESTIMATED ANNUAL HOUR AND COST BURDEN FOR DESIGNATED TREATMENT, STORAGE, AND DISPOSAL FACILITIES (TSDFs) aREJECTED WASTE AND CONTAINER RESIDUES

 Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numbe

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Manife

Enter the name of the person accepting the waste and sign and date each copy of the manifest (or shipping paper, if applicable) 0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 Contact the generator to obtain the generator’s instructions for forwarding the waste to another facility that can manage the waste 0.00 0.00 0.08 0.00 0.08 $3.24 $2.00 Complete Item 18a and 18b of the original manifest, as applicable 0.00 0.00 0.08 0.00 0.08 $3.24 $0.00 Retain a copy of the manifest (or shipping paper) for at least three years from the date of delivery 0.00 0.00 0.00 0.17 0.17 $3.81 $0.00 Give the remaining copies back to the transporter 0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 

a Exhibit contains rounding error.

Hours per TSDF

Rejected waste and container residuesRejection of Waste while the Transporter Remains Present at the Facility 
EXHIBIT 16 (CONTINUED)ESTIMATED ANNUAL HOUR AND COST BURDEN FOR DESIGNATED TREATMENT, STORAGE, AND DISPOSAL FACILITIES (TSDFs) aREJECTED WASTE AND CONTAINER RESIDUES

 Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numbe

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Manife

Enter the name of the person accepting the waste and sign and date each copy of the manifest (or shipping paper, if applicable) 0.00 0.00 0.01 0.00 0.01 $0.40 $0.00 Complete the management method code 0.00 0.00 0.02 0.00 0.02 $0.81 $0.00 Note any discrepancies on each copy of the manifest (or shipping paper, if applicable) 0.00 0.00 0.08 0.00 0.08 $3.24 $0.00 Immediately give the transporter at least one copy of the manifest (or shipping paper) 0.00 0.00 0.17 0.00 0.17 $6.87 $0.00 Within 30 days of delivery, send a copy of the manifest (or shipping paper) to the generator 0.00 0.00 0.00 0.16 0.16 $3.58 $0.52 Retain a copy of the manifest (or shipping paper) for at least three years from the date of delivery 0.00 0.00 0.00 0.17 0.17 $3.81 $0.00 TOTAL 0.00 0.00 varies varies varies varies varies 

a Exhibit contains rounding error.

Manifest completion, transmittal and recordkeeping by Alternate TSDFs

Hours per TSDF

EXHIBIT 17ESTIMATED ANNUAL HOUR AND COST BURDEN FOR DESIGNATED TREATMENT, STORAGE, AND DISPOSAL FACILITIES (TSDFs) aUNMANIFESTED WASTE REPORTS

 Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Numbe

@ $96.98/hr @ $81.73/hr @ $40.44/hr @ $22.40/hr Respondent Respondent Respondent Shipm

Prepare and submit to EPA a letter of the unmanifested waste within 15 days after receiving waste 0.00 0.50 1.00 0.50 2.00 $92.50 $0.62 TOTAL 0.00 0.50 1.00 0.50 2.00 $92.50 $0.62 

a Exhibit contains rounding error.

Hours per TSDF

Unmanifested waste report: completion and submission
54

(d3) Transmitting the Manifest and Reporting to EPA

Exhibit 15 presents the burden to designated TSDFs for receiving and completing manifests that 

are not rejected and that do not result in a container residue. 

(d4) Compliance with State Program Requirements

40 CFR 264.71(e) and 265.71(e) provides that TSDFs must determine whether they are required 

to comply with requirements specific to State hazardous waste manifest programs. EPA assumes 

that each TSDF must contact, on average, three State manifest programs each year. Because 

these activities are performed to learn about state-specific requirements and not the federal 

program, they are not burdened in this ICR. This is reflected in Exhibit 15. 

 (d5) Discrepancy Reports

As reflected in Exhibit 15, EPA estimates that approximately 25% of manifests accepted by the 

designated TSDF require reconciling discrepancies between the manifest data and the shipment 

(e.g. by phoning the generator). EPA further estimates that about 0.4% of manifests accepted by 

the designated TSDF will require a discrepancy report under 40 CFR 264.72 or 265.72. 

(d6) Rejected Waste and Container Residues

Exhibit 16 shows the number of rejected loads and container residues each year. It shows that a 

small percentage of loads and residues will be rejected or identified after the transporter has left 

the designated TSDF’s premises, whereas others will be rejected or identified while the 

transporter is still on the designated TSDF’s premises. Finally, it shows that the designated 

TSDF will forward some of these shipments to an alternate TSDF. [See Exhibit 8 for shipments 

returned to the generator.] 

(d7) Unmanifested Waste Reports: Completion and Submission

As reflected in Exhibit 17, EPA estimates that the manifest will get lost or destroyed during 

transportation for 0.01% of shipments. The designated TSDF will be required to notify the 

Agency of these un-manifested waste shipments, as required under 40 CFR 264.76 or 265.76. 

6E. Bottom Line Burden Hours & Cost 

Respondent Tally 

The total number of respondents estimated for this collection is 83,500. This number was 

gathered by adding up the Total Generators in Table 1, 82,958, with the Total Transporters, 471. 

The total respondent tally is 82,958+471= 83,429. This 83,429 number was rounded up to 

83,500. 

Exhibit 18 shows the aggregate annual hour and cost burden to respondents. As shown in the 

exhibit, EPA estimates the annual respondent burden to be 2,555,959 hours and $85,553,718. 
55

The bottom line burden to respondents over three years is estimated to be 7,667,877 hours and 

$256,661,154. 
EXHIBIT 18TOTAL ANNUAL RESPONDENT HOUR AND COST BURDEN BY TYPE OF RESPONDENT AND MANIFESTING ACTIVITY a

Total Hourly Total Annual Total Annual Total Annual Total Annual

Burden Capital Costs O&M Costs Labor Costs Costs

Reading the regulations 1 $0 $0 $61 $61Applying to the registry 2 $0 $1,302 $128 $1,430Updating general information in the approved application 1 $0 $2 $67 $69Requesting approval for a new tracking number suffix 0 $0 $0 $0 $0Requesting approval for changes to printing specifications or use of a new printer 0 $0 $1,292 $34 $1,326Typesetting the manifest form subsequent to its approval 0 $0 $0 $0 $0Requesting an exemption 0 $0 $0 $0 $0Notifying EPA of a printing specification violation 0 $0 $2 $10 $12Revising the approved manifest if requested by EPA 0 $0 $0 $0 $0Responding to suspension and revocation procedures 0 $0 $0 $0 $0Subtotal (Registrant Organizations) 4 $0 $2,598 $300 $2,898Reading the regulations 89,292 $0 $0 $4,348,188 $4,348,188Manifest completion (without assistance of designated TSDF) 349,680 $0 $300,473 $12,924,267 $13,224,740Manifest completion (with assistance of designated TSDF) 21,772 $0 $0 $747,522 $747,522Compliance with State program requirements 0 $0 $0 $0 $0Manifest transmittal and recordkeeping 322,179 $0 $67,961 $7,463,938 $7,531,899Undeliverable shipments 112 $0 $0 $4,555 $4,555Rejected waste and container residues 311 $0 $323 $8,981 $9,304Exception report completion, submission, and recordkeeping 19,613 $0 $12,524 $1,079,136 $1,091,660Subtotal (Generators) 802,959 $0 $381,281 $26,576,587 $26,957,868Reading the regulations 589 $0 $0 $28,670 $28,670Manifest completion, transmittal, and recordkeeping (domestic + imports + exports) 524,187 $0 $68,432 $16,429,880 $16,498,312Undeliverable shipments 112 $0 $2,812 $4,555 $7,367Rejected waste and container residues 622 $0 $0 $25,029 $25,029Notification of discharge of hazardous waste 1,032 $0 $0 $50,218 $50,218Subtotal (Transporters) 526,542 $0 $71,244 $16,538,352 $16,609,596Reading the regulations 493 $0 $0 $23,983 $23,983Manifest completion (assisting the generators) 392,631 $0 $320,056 $14,543,309 $14,863,365Manifest transmittal and recordkeeping (domestic + imports) 718,118 $0 $688,666 $21,332,586 $22,021,252Compliance with State program requirements 0 $0 $0 $0 $0Discrepancy report completion and submission 28,431 $0 $665,084 $1,163,652 $1,828,736Rejected waste and container residues 86,507 $0 $188,941 $2,703,699 $2,892,640Unmanifested waste report completion and submission 274 $0 $85 $12,673 $12,758Subtotal (Designated TSDFs) 1,226,454 $0 $1,862,832 $39,779,902 $41,642,734Manifest storage (file cabinets) -- $340,622 -- -- $340,622Subtotal (Capital Costs) -- $340,622 -- -- $340,622TOTAL: ALL RESPONDENTS 2,555,959 $340,622 $2,317,955 $82,895,141 $85,553,718

a Exhibit contains rounding error.

Generators (LQGs, SQGs, TSDFs acting as generators)Annualized Capital CostsTransportersDesignated TSDFsRegistrant Organizations
EXHIBIT 19TOTAL ANNUAL AGENCY HOUR AND COST BURDEN a

 Legal Managerial Technical Clerical Contractor Hours/ Labor Cost/ Capital Costs/ O&M Costs/ 

@ $88.30/hr @ $77.92/hr @ $56.05/hr @ $23.92/hr @ $175.00/hr Respondent Response Response Response 

Review initial application 0.00 0.10 0.40 0.00 0.00 0.50 $30.21 $0.00 $0.00 Notify registrant of EPA's decision regarding its application 0.00 0.00 0.00 0.10 0.00 0.10 $2.39 $0.00 $0.52 Review revised application 0.00 0.10 0.40 0.00 0.00 0.50 $30.21 $0.00 $0.00 If application is approved, provide electronic file of the manifest, continuation sheet, and manifest instructions to approved registrant and request manifest form samples

0.00 0.00 0.00 0.10 0.00 0.10 $2.39 $0.00 $5.26 

Evaluate manifest form samples 0.00 0.10 0.40 0.00 0.00 0.50 $30.21 $0.00 $0.00 Notify registrant of EPA's decision regarding its manifest form samples 0.00 0.00 0.00 0.10 0.00 0.10 $2.39 $0.00 $0.52 Evaluate revised manifest form samples 0.00 0.10 0.40 0.00 0.00 0.50 $30.21 $0.00 $0.00 Review revised application 0.00 0.10 0.40 0.00 0.00 0.50 $30.21 $0.00 $0.00 Review documentation submitted by registrant 0.00 0.10 0.40 0.00 0.00 0.50 $30.21 $0.00 $0.00 Provide new tracking number suffix to registrant 0.00 0.10 0.25 0.10 0.00 0.45 $24.20 $0.00 $0.52 Evaluate manifest form samples 0.00 0.10 0.40 0.00 0.00 0.50 $30.21 $0.00 $0.00 Evaluate revised manifest form samples 0.00 0.10 0.40 0.00 0.00 0.50 $30.21 $0.00 $0.00 Evaluate manifest form samples 0.00 0.10 0.40 0.00 0.00 0.50 $30.21 $0.00 $0.00 Review documentation submitted by registrant 0.00 0.10 0.40 0.00 0.00 0.50 $30.21 $0.00 $0.00 Receive notification that a serious violation of a printing specification 0.00 0.20 0.80 0.00 0.00 1.00 $60.42 $0.00 $0.00 Evaluate revised manifest form samples 0.00 0.10 0.40 0.00 0.00 0.50 $30.21 $0.00 $0.00 Review documentation submitted by registrant 0.00 0.10 0.40 0.00 0.00 0.50 $30.21 $0.00 $0.00 Updating General Information in the Approved ApplicationRevising the Approved Manifest if Requested by EPAApplying to the registryRequesting Approval for a New Tracking Number SuffixRegistrant OrganizationsTypesetting the Manifest Form Subsequent to its ApprovalRequesting an ExemptionRequesting Approval for Changes to Printing Specifications or Use of a New PrinterNotifying EPA of a Printing Specification Violation

 Hours per Agency Respondent

Responding to Suspension and Revocation Procedures
EXHIBIT 19 (CONTINUED)TOTAL ANNUAL AGENCY HOUR AND COST BURDEN a

 Legal Managerial Technical Clerical Contractor Hours/ Labor Cost/ Capital Costs/ O&M Costs/ 

@ $88.30/hr @ $77.92/hr @ $56.05/hr @ $23.92/hr @ $175.00/hr Response Response Response Respondent 

Review exception reports: LQGs 0.00 0.10 0.40 0.00 0.00 0.50 $30.21 $0.00 $0.00 Review exception reports: Commercial TSDFs 0.00 0.10 0.40 0.00 0.00 0.50 $30.21 $0.00 $0.00 Review exception reports: Captive TSDFs 0.00 0.10 0.40 0.00 0.00 0.50 $30.21 $0.00 $0.00 Review exception reports: SQGs 0.00 0.10 0.40 0.00 0.00 0.50 $30.21 $0.00 $0.00 Receive notifications of discharge 0.00 0.20 0.80 0.00 0.00 1.00 $60.42 $0.00 $0.00 Receive import manifests 0.00 0.00 0.10 0.00 0.00 0.10 $5.60 $0.00 $0.00 Review designated TSDF discrepancy reports 0.00 0.10 0.40 0.00 0.00 0.50 $30.21 $0.00 $0.00 Review designated TSDF unmanifested waste reports 0.00 0.10 0.40 0.00 0.00 0.50 $30.21 $0.00 $0.00 TOTAL: AGENCY 0.00 varies varies varies varies varies varies varies varies 

a Exhibit contains rounding error.

Discrepancy reportTransporters Unmanifested waste reportGenerators Import ManifestsDesignated TSDFs Notification of dischargeException report

 Hours per Agency Respondent
59

Agency Tally 

Exhibit 19 shows the annual Agency hour and cost burden associated with all the requirements 

covered in this ICR. As shown in this exhibit, EPA estimates the annual Agency burden to be 

13,070 hours and $783,162. The bottom line burden to the Agency over three years is estimated 

to be 39,210 hours and $2,349,486. 

6F. Reasons for Change in Burden 

The currently approved Manifest ICR, Number 801.19, estimates an annual respondent burden of 

3,473,577 hours. This ICR, Number 801.20, estimates an annual respondent burden of 

2,555,959 hours, which is a 917,618-hour decrease from the currently approved ICR. This 

decrease resulted primarily from a decrease in the annual number of generators preparing 

manifests. ICR 801.19 estimates 161,720 generators preparing manifests, whereas ICR 801.20 

estimates 71,434 generators preparing manifests. Table 3 presents a side-by-side comparison of 

these estimates. 

Table 3. Annual Number of Generators Preparing Manifests in ICR 

Generators ICR 801.19 ICR 801.20 

LQGs 14,381 18,001 

Commercial TSDFsa 367 234 

Captive TSDFsa 1,101 703 

SQGs 145,871 52,496b

Total 161,720 71,434 a In general, TSDFs qualify as either LQGs or SQGs. However, EPA has found that TSDFs acting as generators often face 

burdens that are different from generators that are not TSDFs. Therefore, EPA has broken them out separately for purposes of 

examining burden in this analysis. 

b This estimate is preliminary, as EPA is still refining its methodology and estimate. 

The number of generators preparing manifests is a key estimate because it affects the estimated 

number of manifests transmitted, completed, and retained by all waste handlers (i.e., generators, 

transporters, and designated TSDFs) in the manifest cycle.29 This in turn impacts these handlers’ 

estimated manifest burden. ICR 801.19 estimates that 1.88 million manifests are prepared, 

transmitted and retained by waste handlers annually, whereas ICR 801.20 estimates 1.41 million 

manifests annually. 

In preparing ICR 801.20, EPA updated and improved its respondent estimation methodologies, 

which contributed to the change in the number of generators. In general, EPA’s updated 

methodologies utilized a wider range of data sources (e.g., Biennial Report, 3010 notifications, 

Part A submittals) to identify facilities potentially subject to RCRA. EPA then verified that these 

facilities are currently operating and shipping waste by cross-checking multiple data sets using 

their respective EPA identification numbers. This verification step helped to screen out facilities 

 

29 The estimated number of manifests per generator in ICR 801.19 has been left unchanged in ICR 801.20. Hence, 

the number of generators is the key variable causing the difference in the number of manifests (and burden) between 

the two ICRs. 
60

that have gone out of business or stopped shipping hazardous waste and to make other needed 

refinements to the estimates. 30 This verification step was not used in the previous methodology. 

Finally, EPA utilized more reliable methods for determining generator classifications (e.g., 

LQGs vs. SQGs). 

6G. Burden Statement 

The annual public reporting and recordkeeping burden for this collection of information is 

estimated to average 1 hour and 45 minutes per response. Burden means the total time, effort, 

and financial resources expended by persons to generate, maintain, retain, disclose, or provide 

information to or for a Federal agency. This includes the time needed to review instructions; 

develop, acquire, install, and utilize technology and systems for the purposes of collecting, 

validating, and verifying information, processing and maintaining information, and disclosing 

and providing information; adjust the existing ways to comply with any previously applicable 

instructions and requirements; train personnel to be able to respond to a collection of 

information; search data sources; complete and review the collection of information; and 

transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a 

person is not required to respond to, a collection of information unless it displays a currently 

valid OMB control number. The OMB control numbers for EPA’s regulations are listed in 40 

CFR Part 9 and 48 CFR Chapter 15. 

To comment on the Agency’s need for this information, the accuracy of the provided burden 

estimates, and any suggested methods for minimizing respondent burden, including the use of 

automated collection techniques, EPA has established a public docket for this ICR under Docket 

ID No. EPA-HQ-RCRA-2014-0925, which is available for online viewing at 

www.regulations.gov, or in person viewing at the RCRA Docket in the EPA Docket Center 

(EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The 

EPA/DC Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, 

excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and 

the telephone number for RCRA Docket is (202) 566-0270. An electronic version of the public 

docket is available at www.regulations.gov. This site can be used to submit or view public 

comments, access the index listing of the contents of the public docket, and to access those 

documents in the public docket that are available electronically. When in the system, select 

“search,” then key in the Docket ID Number identified above. Also, you can send comments to 

the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th 

Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA 

Docket ID Number EPA-HQ-RCRA-2014-0925 and OMB Control Number 2050-0039 in any 

correspondence. 

 

30 This verification step was particularly helpful for screening out SQGs that are no longer operating or generating 

hazardous waste. Historically, EPA has had difficulty determining the universe of operating SQGs because many of 

them seldom report to EPA or the State. Although they normally notify the State when they originally begin to 

generate hazardous waste, they often do not re-notify when they go out of business, stop generating hazardous waste 

or change generator classification. Hence, EPA’s data systems contain a number of sites whose operating status and 

generator classification are out of date. The verification step helped to address this limitation and resulted in a 

significant decrease in the estimated number of SQGs currently subject to the manifest system. Note that the SQG 

estimate is still preliminary, as EPA is still refining its methodology and estimate.