The Exception Report

When a generator of hazardous waste does not receive a copy of the signed manifest back from the owner or operator of a designated facility within 35 days of shipping the waste to that facility, the generator must file an Exception Report with the EPA. The requirements are different for LQGs and SQGs.

Exception Reports for LQGs

An LQG is supposed to receive a copy of the signed manifest back from the owner or operator of a designated facility within 35 days of the date that the owner or operator accepted the waste from the initial transporter. If the LQG has not received the signed manifest back in that timeframe, the LQG must contact the transporter and/or the owner or operator of the designated facility to determine the status of the hazardous waste. If the LQG has still not received a copy of the signed manifest within 45 days of the date the waste was accepted by the owner or operator of the facility from the initial transporter, the LQG must submit an Exception Report to the EPA regional administrator.

The Exception Report must include the following documents:

• A copy of the manifest for which the generator lacks confirmation of delivery
• A cover letter signed by the generator that explains the efforts made to locate the hazardous waste and the results of those efforts.

Exception Reports for SQGs

An SQG is supposed to receive a copy of the signed manifest back from the owner or operator of a designated facility within 60 days of the date that the owner or operator accepted the waste from the initial transporter. If the SQG has not received the signed manifest back in that time frame, the SQG must submit a legible copy of the manifest, with an indication that the generator has not received confirmation of delivery, to the EPA regional administrator.

To learn more about RCRA safety standards visit our RCRA Refresher Online Training web page.