Illinois Amends Special Waste Manifest Requirements

SEPTEMBER 8, 2020

The Illinois Pollution Control Board has adopted a final rule amending the regulatory requirements governing the shipments of special waste. The final rule was published in the Illinois Federal Register on July 31, 2020, and went into effect on July 20, 2020.

The final rule no longer requires Illinois special waste to be transported on uniform hazardous waste manifests, but instead allows it to be transported on functionally equivalent manifests or shipping documents that capture all required information. The final rule also allows transporters to purchase forms from third-party vendors, removing the previous requirement to use the manifest forms supplied by the state of Illinois.

Previously, the Illinois regulations under 35 Ill. Adm. Code 809 required the use of the U.S. Environmental Protection Agency’s (EPA) uniform hazardous waste manifest for all special waste, both hazardous and non-hazardous. Over the last two years, the Illinois Pollution Control Board has considered changes to its special waste regulations to allow more flexibility for shipping requirements for special wastes.

The regulatory team for Stericycle Environmental Solutions, now Clean Earth, submitted comments to the Illinois Pollution Control Board on the proposed rule changes, supporting the amendments and recommending that regulations allow the use of any shipping document that meets the state’s requirements and removing the requirement to use the state’s specific form that had to be ordered from and supplied by the state.

Special waste in Illinois is hazardous waste, potentially infectious medical waste (PIMW), industrial process waste and pollution control waste. Examples of special waste include wastes with free liquids, like used oil, cutting oils, industrial lubricants and other types of industrial wastes, such as sludges, asbestos, polychlorinated biphenyls (PCBs), paint sludges, equipment cleanings, metallic dust sweepings, used solvents from parts cleaners and off-specification, contaminated or recalled wholesale or retail products. Non-hazardous pharmaceutical waste and regulated medical waste are also considered special waste in Illinois.

The Illinois EPA’s website on special waste requirements offers insight for special waste generators as well as guidance for waste transporters regarding the use of manifests.

Clean Earth remains on the forefront of the latest regulations affecting your business. We provide safe, reliable transportation solutions for all hazardous and non-hazardous wastes. Learn more about our nationwide transportation services here.