Shipment Discrepancies

Sometimes what is shipped may not match the information on the manifest. The regulations spell out what qualifies as a "discrepancy" in a shipment of hazardous wastes. A discrepancy is when the following situations occur:

• There is a difference between the quantity or type of hazardous waste listed on the manifest versus that which is actually received.
• The wastes are rejected by the receiver, either in full or in part.
• Container residues exceed the quantity limits for "empty" containers as described in 40 CFR 264.7(b).

Each of these discrepancies is subject to its own set of guidelines. In general, if there is a discrepancy, the receiver must work to ensure that the issue is resolved with the waste generator, and that during this time, the shipment is not improperly disposed of. An amended manifest or a new manifest may be required for the rejected or re-routed shipments. Note that if a facility accepts any hazardous waste from an off-site source, and it is not received with a manifest or shipping paper, the facility owner or operator must inform the EPA regional administrator within 15 days of receiving the waste. The owner or operator must provide information about the waste, including a brief explanation of why the waste was not manifested, if that reason is known.

To learn more about RCRA visit our RCRA Hazardous Waste Safety Online Training web page.