Household
Hazardous
Waste
SOP 3.6: Manifests and Land Disposal
Restrictions
Contents
1.
2.
3.
4.
5.
6.
Introduction ...................................................................................1
Regulatory and contractual requirements ....................................1
Manifest components ....................................................................2
Tracking hazardous waste with manifests .....................................3
Land disposal restriction information ............................................4
Paint Stewardship Program information .......................................4
1. Introduction
Minnesota rules require generators and transporters of hazardous waste (HW) to use a manifest form. A
manifest is a multi-page shipping paper that may accompany HW. It is a cradle-to-grave tracking record of HW
from the time it leaves the facility (the cradle) until it reaches the proper disposal destination (the grave). The
generator is ultimately responsible for the information on the manifest. Tracking HW helps to ensure it is
managed and disposed of in a manner that does not pose a risk to human health or the environment. See
Standard Operating Procedure (SOP) 4.14 Shipping Papers and Tracking Waste.
Land Disposal Restrictions (LDRs), which accompany each manifest throughout shipment, prohibit the disposal
of HW on the land unless the HW meets specified treatment standards. This Household Hazardous Waste (HHW)
program is a HW Generator and has been issued a Minnesota Pollution Control Agency (MPCA) HW Generator
Identification (ID) number prior to shipping HW. For this SOP U.S. Environmental Protection Agency ID numbers
will be referred to as Generator HW ID numbers.
2. Regulatory and contractual requirements
Manifests and/or shipping papers are governed by the requirements established in the authorizing state agency
contract, Department of Transportation Hazardous Materials Rules 49 Code of Federal Regulations 100-185 and
172.704, 172.602 A-C and 172.604 A-B, Minn. Stat. ch. 221, Minn. Rules: 7045.0310, subp. 3. B, C, and 3. C.1;
subp. 5. B, 5. C.1-2.; subp. 6 and 6. 1; 7045.0261; 7045.0351-.0397; 7045.0395 and 7045.0391 and (if applicable),
Minnesota Paint Stewardship Program section 1415, Ch. 115A.
3. Manifest components
3.1 Manifest signatures
Program staff may not sign manifests or shipping papers on behalf of the State until first receiving
permission from the State’s MPCA authorized representative. See SOP 3.5 Demonstration for Manifest
Signature.
3.2 Completion of a manifest
3.2.1
The manifest form is a multi-page document, so signing the document requires the use of a
good ballpoint pen, to press hard to ensure the last copy is as legible as the first. For
additional information see Attachment A of this SOP.
w-hhwsop3-06 - Manifests and Land Disposal Restrictions
March 2015
1
3.2.2
Staff responsible for signing manifests or shipping papers ensures document accuracy by
following the numbered items on the manifest form, including:

generator’s HW ID number, name, mailing address and site address

transporter’s generator HW ID number and name

designated facility’s generator HW ID number, name and site address

proper shipping name, hazard class, waste ID number, packing group (if any), total
quantity, unit of measure and waste codes

HW generator, transporter and designated facility’s name, signature, and shipment date

correct number of pages, as indicated on the first page of the manifest

24-hour emergency number and manifest discrepancy contact information
3.3 Manifest copies
3.3.1
Facility staff may become familiar with the manifest document. To review a uniform HW
manifest copy, see http://www.epa.gov/osw/hazard/transportation/manifest/index.htm.The
transporter will leave a copy at the facility and the remaining five pages will accompany the
waste. These copies will be distributed as follows:

Copy 1 – Designated facility to destination state copy (if required); a designated facility is
the end HW disposal site. Copy 1 is sent to the destination state within 10 days after
waste has been picked up by state contracted HW disposal company.

Copy 2 – Designated facility to generator state copy (if required); sent to the generator
state within ten days.

Copy 3 – Designated facility to generator copy; sent to the generator within 30 days; also
referred to as the three signature or final copy. Copy 3 contains three signatures; HHW
program, transporter and the designated (end disposal) facility. When the waste is
accepted at the designated facility, they will sign and date Copy 3 and mail it back to the
generator.

Copy 4 – Designated facility copy; retained by designated facility or end disposal site.

Copy 5 – Transporter copy; retained by the transporter. After both the generator and the
transporter sign and date the manifest, copies 1-5 accompanies the waste during
transport.

3.3.2
3.3.3
Copy 6 – Generator’s initial copy; retained by the HHW program and may be referred to
as the two-signature copy (or initial copy).
Proper manifest documentation and recordkeeping from each waste shipment may include
three pages; manifest Copy 3, manifest Copy 6, and the corresponding LDR. Retain manifests
and LDRs for at least three years (preferably indefinitely).
Ensure manifests and shipping papers are accessible for inspection (this requirement also
pertains to HHW programs operating mobile collection events).
4. Tracking HW with manifests
4.1 Shipping day
1. Set a manifest return due-date reminder 35 days from the date HW is shipped out from this
facility. Retain LDR and Copy 6–Generator’s Initial Copy.
2. If necessary, the state’s HW disposal company mails Copy 6–Generator’s initial copy to the MPCA.
w-hhwsop3-06 - Manifests and Land Disposal Restrictions
March 2015
2
4.2 Manifest arrival
1. On the date Copy 3–Designated facility to generator copy is received, photocopy and forward to
MPCA.
2. Attach Copy 3 to Copy 6 and the corresponding LDR form (left on site the day of shipment) and file
all three documents in a location readily accessible for inspections.
3. Indicate on facility calendar that the matching manifest copy has been received.
4.3 If manifest does not arrive within 35 days
1. Check to see if manifest copy has already been filed.
2. If a manifest copy has not yet been received, contact HW disposal company to inquire status.
3. If Copy 3 does not arrive within 10 additional days (45 days after the shipment date), photocopy
Copy 6. Draft a note to MPCA explaining the problem and efforts made to resolve it.
5. Land disposal restrictions information
5.1 The Hazardous and Solid Waste Amendments of 1984 greatly restricted the land disposal of untreated
wastes prior to land disposal. If a waste meets applicable LDR treatment standards, the generator
submits a one-time initial notification, which may accompany the manifest during shipment, including:

generator’s HW ID number; see http://www.pca.state.mn.us/index.php/waste/waste-monitoringand-reporting/epa-id-search/hazardous-waste-identification-number-search.html

manifest number associated with the shipment

applicable waste codes

applicable wastewater or non-wastewater category

applicable subdivision for each waste code

waste analysis data (when available)
5.2 LDR requirements generally apply to wastes that are a listed HW or are hazardous due to a hazardous
characteristic.
5.3 Keep LDR information with corresponding manifests for a minimum of three years (preferably
indefinitely).
6. Paint Stewardship Program information
If your facility participates in the Minnesota Paint Stewardship Program, additional documentation is likely
required; see http://www.paintcare.org/wp-content/uploads/docs/mn-factsheet-hhw.pdf.
w-hhwsop3-06 - Manifests and Land Disposal Restrictions
March 2015
3