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Manifest Management: 3 Folder System

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By Ian Lanza, Life Sciences Operations Manager

The Resource Conservation and Restoration Act (RCRA) requires hazardous waste generators to retain hazardous waste manifests for up to three years. Generators are responsible for keeping the Generator's Copy of the federal hazardous waste manifests, as well as a returned copy from the treatment, storage, disposal or facility within 45 days of the signing and shipping the hazardous waste from the generator’s site.

The 3 folder system to hazardous waste manifest management is an easy way for all hazardous waste generators to compliantly managed their hazardous waste manifest:

  1. In a filing cabinet, set up three folders for your hazardous waste manifests.
  2. Upon shipping waste from your facility, place the ‘Generator's Copy' in the first folder.
  3. The second folder is for manifests returned from the TSDF.
  4. Once the return copy has been received by the generator, move the manifest copies to the third folder. Manifests should remain in the third folder for three years.

If you do not receive a return copy of the hazardous waste manifest within 35 days, you must contact the TSDF to determine the status of the manifest.  The 3 folder manifest management system is a simple way to track and file hazardous waste manifests and comply with the RCRA regulations.


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