Special Waste Requirements

The following outlines requirements to manifest, report and maintain records for special waste.

Special Waste Manifesting Requirements

Special waste generators, shippers/transporters and receiving facilities must all follow manifesting requirements.1 A federal manifest, shipping paper or shipping record may be used as long as it includes all the information required on the Arizona state manifest form.2

Special Waste Generator Manifesting Requirements

  • Prior to shipping special waste off-site complete the “Generator” section of the manifest making sure to sign and date.
  • Have the shipper/transporter sign and date the manifest in the “Transporter” section of the manifest.
  • Keep the green “Generator File Copy” of the manifest for your records
  • Within 14 days after shipping waste send the pink “ADEQ – File Copy” to ADEQ.
  • Give the remaining copies to the shipper/transporter or forward to the receiving facility.
  • Once the waste leaves the site — follow up, within 35 days the generator should receive the completed white “Original” copy of the manifest from the Receiving Facility.
  • All copies of the manifest must be legible.

What to do if things go wrong:

  • If the generator does not receive a copy of the manifest within 35 days, contact the special waste shipper/transporter and the receiving facility to determine the status of the special waste.
  • If, within 45 days after shipping the waste, the generator still has not received a signed completed copy of the manifest from the facility submit an exception report to ADEQ containing:
    • A cover letter signed by the Generator explaining what you have done to locate the waste and what was discovered
    • A legible copy of the generator’s copy of the manifest with signatures of the generator and shipper

Special Waste Shipper/Transporter Manifesting Requirements

  • Before the shipper/transporter leaves with the waste, accept the waste for shipment only when it is accompanied by a special waste manifest with the “Generator” section of the manifest completed and signed by the generator.
  • Verify the Shipper/Transporter special waste ID number is correct on the manifest
  • Sign and date the “Transporter” section of the manifest.
  • Leave the Generator File Copy and ADEQ File Copy of the manifest with the Generator
  • Deliver the entire shipment of special waste to the receiving facility designated on the manifest
  • Retain the gold “Shipper/Transporter File Copy” of the manifest for your records

When shipping special waste make sure that the transporting vehicles are constructed to prevent spills and leaks and are covered to prevent blowing of material.

What to do if things go wrong:
If the shipper/transporter is unable to deliver the special waste to the primary or alternate receiving facility designated on the manifest, either:

  • Return the special waste to the generator, or
  • Contact the generator for instructions and deliver the waste accordingly.

Special Waste Receiving Facility Manifesting Requirements

  • Receive only special waste accompanied by a manifest signed and dated by the generator and shipper.
  • In the “Facility” section of the manifest, the receiving facility operator is required to complete all of the following:
    • Enter the Special Waste ID
    • Sign and date each copy of the manifest to certify that the type and amount of waste received matches that stated on the manifest
    • Indicate on the manifest any significant discrepancies between the description, volume, or weight of the special waste stated on the manifest and the waste received.*
    • Keep the blue “Receiving Facility File Copy” for your records
    • Send the yellow “ADEQ –Verification” copy to ADEQ and the white “Original Copy” to the generator within 30 days of delivery of the waste.

* A significant manifest discrepancy means a difference of more than 10% by weight for bulk shipments, any variation in a piece count for batch delivery, or any difference in the type of special waste received as compared to the type of special waste listed on the manifest.3

What to do if things go wrong:
If the receiving facility operator discovers a significant manifest discrepancy between the manifest waste and the waste received, the receiving facility operator is required to:

  • Contact the generator and shipper/transporter to try to reconcile the discrepancy.
  • If the discrepancy cannot be resolved within 15 days after receiving the waste, submit the manifest to ADEQ with a letter describing the significant manifest discrepancy and all attempts to reconcile it.

To print out this information see Special Waste Manifesting Fact Sheet | Download >

Special Waste Annual Report Requirements

The following handlers of special waste must submit a Special Waste Annual Report Form by March 1st of each year for all special waste shipped the preceding year:4

  • Any Generator who treats, stores, or disposes of special waste on-site, off-site, and/or a generator who ships special waste for purposes of treatment, recycling, storage or disposal  to an off-site facility managed by that generator. Special Waste Generator Annual Report Instructions and Form | Download>
  • Any shipper/transporter. Special Waste Transporter Annual Report Instructions and Form | Download>
  • Any facility that receives special waste from off-site for the purposes of treatment, storage, or disposal. Special Waste Receiving Facility Annual Report Instructions and Form | Download>

A facility with an active Special Waste ID number is required to submit an annual report form each year even if special waste had not been generated or shipped the previous year. If you need to deactivate your special waste ID number please fill out an application form and submit it to ADEQ | Learn More >

Special Waste Record Keeping Requirements

Keep all special waste records for at least 3 years. If you are notified of an enforcement action by ADEQ, records are required to be kept until a final determination has been made in the matter or in accordance with the final determination.5