What Must Be Included on a Hazardous Waste Manifest?

A complete Uniform Hazardous Waste Manifest (EPA Form 8700-22) must include a pre-printed tracking number, a 24-hour emergency response phone number, full identification and EPA ID numbers for the generator, every transporter, and the designated receiving facility, a Department of Transportation shipping description for each waste, the applicable EPA and state waste codes, container counts and total quantities with units of measure, any special handling instructions, and dated signatures from the generator, each transporter, and the receiving facility, along with the waste minimization certification that matches the generator’s size category.¹ Every field matters. Civil penalties for manifest violations reach $93,058 per day under the current inflation adjustment, so a missing signature or a wrong waste code is not a clerical problem.²

Tracking Number and 24-Hour Emergency Phone

The top of every manifest carries a unique tracking number pre-printed by an EPA-registered forms printer. It runs nine digits followed by a three-letter suffix, giving the shipment a 12-character identifier that EPA and state agencies use to catalog it in the national database.³ Generators do not create this number themselves; it comes on the form.

Directly below the tracking number, the generator must enter a 24-hour emergency response phone number. The line has to be monitored around the clock for the entire time the waste is in transit, and the person answering needs to know the shipped material well enough to advise first responders during a spill or accident on the road.⁴ A general office line that rolls to voicemail after 5 p.m. does not satisfy the requirement.

Generator, Transporter, and Facility Identification

The manifest must clearly identify every party that touches the waste. For the generator, each transporter, and the designated receiving facility, the form calls for a name, mailing address, and EPA Identification Number. The EPA ID is a 12-character code beginning with a two-letter state abbreviation followed by ten alphanumeric characters, and no entity can legally ship, transport, or receive hazardous waste without one.⁵

The generator designates one permitted facility as the primary destination and may list one alternate in case an emergency prevents delivery to the first choice. Each trucking company that handles the load gets its own line. The standard form has room for two transporters; when a shipment needs three or more, the generator attaches a continuation sheet (EPA Form 8700-22A).⁴ Together, these entries build the chain of custody regulators use to trace waste back to its source after a spill or improper disposal.

DOT Shipping Description for Each Waste

The heart of the manifest is the waste description block, which follows Department of Transportation shipping paper rules under 49 CFR Part 172. For each waste line, the generator must provide four items:

The proper shipping name from the DOT Hazardous Materials Table, for example “Waste Flammable Liquids, n.o.s.”
The hazard class or division number, such as Class 3 for flammable liquids.
The identification number, a four-digit code preceded by “UN” or “NA” that pinpoints the specific substance.
The packing group, a Roman numeral (I, II, or III) showing how dangerous the material is within its hazard class, with Group I the most severe. Some materials, such as explosives, have no packing group assigned.⁶

EPA and State Waste Codes

Each waste stream on the manifest must be tagged with the correct EPA hazardous waste codes. They fall into two broad families. Characteristic waste codes (D001 through D043) describe properties like ignitability or toxicity. Listed waste codes use letter prefixes: F-codes for wastes from common industrial processes, K-codes for wastes from specific industries, and P- and U-codes for discarded commercial chemical products. A single waste stream can carry multiple codes if it has more than one hazardous characteristic or appears on more than one EPA list.

Some states add their own codes on top of the federal ones. The generator is responsible for applying every applicable code before the shipment leaves the site, which usually requires a formal waste characterization or laboratory testing. Incorrect codes can route waste to a facility that is not equipped to handle it, which is exactly the kind of mistake that draws enforcement attention.

Container Count, Quantity, and Unit of Measure

Below the DOT description, the generator records the number and type of containers (metal drums, fiberboard boxes, tanker loads, and so on) and the total quantity of waste being shipped, with the appropriate unit of measure.⁴ These numbers matter because emergency crews need to know whether they are facing a single drum or twenty, and disposal facilities need accurate weights to manage incoming loads.

Special Handling Instructions (Item 14)

Item 14 is a free-text field for any information the generator, transporter, or receiving facility needs beyond what the structured fields capture. Generators commonly use this space for waste profile numbers, response guide numbers, chemical names, constituent percentages, physical state descriptions, and container-specific bar codes.⁷

This field is also the catch-all for certain federally required information that has no dedicated box, such as alternate facility designations, the original manifest tracking number for rejected wastes being re-shipped, and PCB waste descriptions with their out-of-service dates. States cannot force generators to use this space to satisfy state-specific reporting rules.

Certification and Signatures (Item 15)

Item 15 contains a certification statement the generator must sign before the waste leaves the site. The wording depends on the generator’s size category. Large quantity generators certify that they have a program in place to reduce the volume and toxicity of their waste to the degree they find economically practicable, and that they have chosen the disposal method that best minimizes threats to human health and the environment. Small quantity generators certify that they have made a good faith effort to minimize waste and selected the best management method they can afford.⁸

By signing, the generator also confirms that the waste is properly classified, described, packaged, marked, and labeled for transport. The initial transporter signs and dates the manifest when physically accepting the waste, and any additional transporter signs upon taking custody. At the destination, the receiving facility’s owner or operator signs and dates every copy to confirm arrival, noting any discrepancy between what the manifest describes and what actually showed up.⁹ On paper manifests, all signatures must be handwritten. Fully electronic manifests use CROMERR-compliant electronic signatures instead.¹⁰

Who Is Exempt From the Manifest

The manifest is required for shipments from large quantity generators (1,000 kilograms or more of non-acute hazardous waste per month) and small quantity generators (100 to 1,000 kilograms per month). The two categories fill out the same form, but the waste minimization certification wording differs.¹¹

Very small quantity generators (100 kilograms or less per month) are generally exempt from manifest requirements, though the exemption disappears if they accumulate more than 1,000 kilograms of non-acute hazardous waste or more than 1 kilogram of acute hazardous waste on site.¹² VSQGs within those limits still have to deliver waste to an authorized facility, but the manifest paperwork does not apply.

Why Every Field Matters

RCRA gives EPA broad authority to impose civil and criminal penalties for manifest-related violations, including incomplete forms, missing signatures, and wrong waste codes. Civil penalties can reach $93,058 per day under the January 2025 inflation adjustment.² Criminal violations, such as knowingly transporting hazardous waste without a manifest, carry up to two years in prison and fines of up to $50,000 per day, with penalties doubling for repeat offenders.¹³ A single shipment with the wrong waste code or a missing transporter signature can generate five- or six-figure liability before anyone realizes there is a problem. Build a consistent internal review that catches errors before the truck pulls away from the dock.

1
US EPA. Resource Conservation and Recovery Act (RCRA) Overview
2
eCFR. 40 CFR Part 19 – Adjustment of Civil Monetary Penalties for Inflation
3
eCFR. 40 CFR 262.21 – Manifest Tracking Numbers, Manifest Printing, and Obtaining Manifests
4
U.S. Environmental Protection Agency. Hazardous Waste Manifest Instructions
5
Government Publishing Office. 40 CFR 262.20 – General Requirements
6
eCFR. 49 CFR Part 172 – Hazardous Materials Table, Special Provisions, Hazardous Materials Communications
7
U.S. Environmental Protection Agency. Instructions for Completing the Uniform Hazardous Waste Manifest
8
eCFR. 40 CFR 262.27 – Waste Minimization Certification
9
eCFR. 40 CFR 264.71 – Use of Manifest System
10
US EPA. How to Submit a Hazardous Waste Manifest
11
US EPA. Categories of Hazardous Waste Generators
12
eCFR. 40 CFR 262.14 – Conditions for Exemption for a Very Small Quantity Generator
13
US EPA. Criminal Provisions of the Resource Conservation and Recovery Act (RCRA)