December 15, 2005Client Alert

U.S. EPA Adopts New Rules Regulating Hazardous Waste Manifest Forms

The United States Environmental Protection Agency (EPA) recently adopted new rules regulating the printing and distribution of hazardous waste manifest forms. The new rules seek to require nationwide uniformity of hazardous waste manifest forms, including establishing a printer registration and form approval process.  In addition, the rules mandate a new method for numbering manifests which ensure numbering is uniform at a national level, in contrast to the historic method which has resulted in a variety of numbering formats based on state requirements. 

The substantive and procedural changes imposed by the new rules become effective as of September 6, 2005,and the compliance period continues for one year.  Thus, the new mandated hazardous waste manifest forms, including the printer registration and form approval process, will become mandatory September 6, 2006 for all persons and entities printing, using or distributing hazardous waste manifest forms.

For more information, please visit the EPA site at

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