Plain English Guide to Regulations
Solid/Hazardous Waste Management

Reporting and Recordkeeping

Biennial Report (SQGs and LQGs only)
SQGs and LQGs who ship hazardous waste off-site to a TSDF must prepare and submit a Biennial Report to the EPA Regional Administrator by March 1 of each even numbered year 2008, 2010, 2012, etc.). Use EPA Form 8700–13A for submitting the report, and include the following information:
  • The EPA identification number, name, and address of the generator;
  • The calendar year covered by the report
  • Your EPA identification number, name, and address for each off-site treatment, storage, or disposal facility to which waste was shipped
  • The name and EPA identification number of each transporter used
  • A description, EPA hazardous waste number (from 40 CFR part 261, subpart C or D), DOT hazard class, and quantity of each hazardous waste shipped off-site
  • A description of the efforts undertaken during the year to reduce the volume and toxicity of waste generated.
  • A description of the changes in volume and toxicity of waste actually achieved during the year in comparison to previous years
  • The certification signed by the generator or authorized representative.
Exception Reporting (SQGs and LQGs only)
Exception reports are part of the RCRA tracking system. After you send waste off-site for disposal, the TSDF is required to return to you a copy of the original manifest. If you dont receive the manifest from the TSDF, then you must submit an Exception Report. SQGs must file a Exception Report if they have not received a copy of the manifest with the handwritten signature of the owner or operator of the designated facility within 45 days of the date the waste was accepted by the initial transporter. There is no special form for the Exception Report. You can write directly on a copy of the manifest or attach a separate sheet of paper (handwritten or typed). Make sure you include:
  • A legible copy of the manifest in question
  • A statement explaining the efforts taken to locate the hazardous waste
  • Your signature
The Exception Reprting requirements for LQGs are a little different. If you do not receive a copy of the manifest within 35 days of the date that the waste was accepted by the original transporter, you must contact the transporter and TSDF to determine the status of the waste. If you still havent received a copy of the manifest within 45 days, then you must submit the Exception Report as described above for SQGs.

You must retain records for three years, including:

  • Manifests
  • Biennial Reports
  • Exception Reports
  • Any test results, waste analyses, or similar information related to the waste shipped off-site
  • Your inspection schedule and reports. (Specific inspection requirements are found in 40 CFR 265.15.)
The three-year time period is automatically extended indefinitely if you have any unresolved enforcement action. In this case, maintain the files until all matters are fully resolved.



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You should consult with legal counsel and appropriate authorities before interpreting any regulations or undertaking any specific course of action.

Please note that many of the regulatory discussions on STERC refer to federal regulations. In many cases, states or local governments have promulgated relevant rules and standards
that are different and/or more stringent than the federal regulations. Therefore, to assure full compliance, you should investigate and comply with all applicable federal, state and local regulations.