Being a generator of hazardous waste comes with many challenges, none more complicated than the Uniform Hazardous Waste Manifest.
But did you know that Texas requires specific information for its hazardous waste manifests?
This guide helps you better understand everything you need to know about Uniform Hazardous Waste Manifests, including how to complete the form in Texas, and how working with a hazardous waste disposal company like HWH Environmental can assist you.
What is a Uniform Hazardous Waste Manifest?
The Uniform Hazardous Waste Manifest is a required shipping document that traces hazardous waste from its creation to its final destination.
As a hazardous waste generator, you are responsible for the waste from ‘cradle to grave.’ As part of that process, you need a uniform hazardous waste manifest in case of an audit.
The EPA and DOT require this form to track hazardous waste and include details about the type and quantity of the waste.
In Texas, a Uniform Hazardous Waste Manifest is required by law for all off-site shipments of both hazardous waste and the state’s unique Class 1 industrial waste.
Once the hazardous waste has reached its final facility, a signed copy of the manifest is returned to the generator for confirmation.
For the state of Texas, regulations allow hazardous waste generators to use paper manifests, electronic manifests (e-manifests), or a hybrid of the two.
The Texas-Specific Hazardous Waste Manifest
The Texas Commission on Environmental Quality does not require you to submit the manifest; however, there are specific Texas regulations that you must follow.
For any hazardous waste generators in Texas, you must include the state’s specific 8-digit waste code. Waste codes help identify each waste stream.
This unique code must be included in Item 13 of the manifest and is a frequent source of error for businesses unfamiliar with the state’s rules.
The formula for the Texas Waste Code is:
“The 4-digit sequence number + the 3-digit form code + the 1-digit classification code.”
Texas provides this online guide to help if you have additional questions about the waste codes or need assistance.
The state highlights that one of the most common violations for small quantity and large quantity hazardous waste generators is the “Listing incorrect Texas Waste Code Nos.”
Filling Out the Texas Hazardous Waste Manifest
The generator must include their name and the physical address of the facility that’s responsible for creating the waste. This must match the information on your Notice of Registration (NOR).
You’ll also need to include the generator’s EPA ID Number if you’re an SQG and LQG. Some Exempt Small Quantity Generators (CESQGs, now called VSQGs) don’t need to include this number.
The manifest number (Item 4) is a pre-printed, unique number that identifies the specific manifest.
Next is the transporter. The transporter is the company that is hauling your hazardous waste off-site.
The names and EPA ID numbers of the one or two licensed transporters who will be moving your waste are listed in Item 6.
The EPA ID is crucial; using an unpermitted transporter is a serious offense.
If you’ve worked with the same hazardous waste hauler, you probably already have this information available to you. It is the generator’s responsibility to complete this section of the manifest.
The third section describes the waste. This section is where you’ll put in the Texas Waste Codes (Item 13), as well as waste descriptions and quantities.
For quantities, the EPA and DOT require the number and type of containers.
Lastly, a trained employee on hazardous waste regulations must sign and date the manifest.
This signature certifies that the waste has been properly classified, packaged, and labeled for transport in compliance with federal and state regulations.
But once the waste leaves your facility, the generator is still responsible for following up on any hazardous waste manifests.
The TCEQ requires that you receive a signed copy of the manifest from the designated disposal facility.
If you do not receive a copy back within 35 days, you must contact the facility to investigate the issue.
If you still have not received a signed copy within 45 days, you must file an exception report with the TCEQ’s Executive Director.
All signed hazardous waste manifests must be kept for a minimum of 3 years.
Common Hazardous Waste Manifest-Related Violations
According to TCEQ information, most violations are attributed to procedural or administrative errors.
The three most common violations include incorrect manifest completion (wrong waste codes), failure to follow up, and inadequate training.
Fines from the EPA regarding incorrect manifests could reach as much as $81,540 per day, while Texas commonly fines between $50 and $25,000 per day, per violation.
If you do not follow up, those violations will be treated as record-keeping violations and could result in fines of thousands of dollars per day.
Texas and the EPA require all SQGs and LQGs to train their employees; otherwise, they could face fines of $10,000–$25,000 per day, per violation, along with the additional risk of employees mishandling wastes, which could lead to even more severe problems.
How HWH Environmental Helps Businesses
With over 25 years of experience handling and disposing of hazardous waste across the United States, we work with businesses in the great state of Texas to dispose of their hazardous waste with care, in accordance with EPA and State regulations.
When you call HWH Environmental, you reach a live human being instead of an automated voice system. Our team customizes your disposal solutions, providing detailed pricing and flexible scheduling.
If you need help with your Texas waste manifest or have hazardous waste that needs to be disposed of, contact HWH Environmental today.
