Illinois Considers Special Manifest Requirements

MAY 11, 2019

Illinois is considering special manifest requirements for non-hazardous waste. This would solve an issue that exists today, as “special waste” must be shipped on a Uniform Hazardous Waste Manifest.

“Special waste” generally refers to all non-hazardous waste in Illinois, including non-hazardous pharmaceutical waste. As a result, this designation has created complications because of the U.S. Environmental Protection Agency’s (EPA) new e-Manifest system, which requires all manifests signed by generators on or after June 30, 2019, to be submitted to the system.

The purpose of the new e-Manifest system is to improve access to higher quality and more timely hazardous waste shipment data and save industry and states valuable time and resources to the tune of $90 million annually. The generator regulations ensure that hazardous waste is appropriately identified and handled safely to protect human health and the environment, while minimizing interference with daily business operations.

What’s the issue for Illinois?

Due to the e-Manifest rule, these non-hazardous wastes in Illinois are currently required to be uploaded to the system. To eliminate the issue, the Illinois EPA has proposed that transporters use “functionally identical” manifests to track special waste. These manifests would not be required to be uploaded to the e-Manifest system.

This proposal would eliminate the burden of uploading and paying for these manifests to be put into the system. Therefore, if the change passes, these documents will no longer live in the e-Manifest system.

As e-Manifest changes are implemented, Clean Earth is committed to ensuring we update our customers regularly. To submit a question to Clean Earth about e-Manifest regulations, click here.