epahazardous-wastemanifestssuperfundcerclacontractorsregulatory-update

EPA Proposes New Contractor Manifest Signing Authority - Streamlining Hazardous Waste Removal at Federal Sites

EPA proposed a new Environmental Protection Agency Acquisition Regulation (EPAAR) provision that would allow contractors to sign Uniform Hazardous Waste Manifests at all EPA worksites, not just Superfund sites. The current local clause restricts contractor manifest signing authority to Superfund sites only. The proposed rule would expand this authority to cover hazardous and non-hazardous material removal at both Superfund and non-Superfund federal facilities.

What the Current Rule Says

Under existing EPA acquisition regulations, contractors can sign waste manifests only at Superfund sites. This creates operational delays at non-Superfund EPA facilities when EPA personnel are unavailable to sign manifests for waste removal activities.

The proposed EPAAR provision would establish uniform manifest signing authority across all EPA worksites. What this means in practice: contractors performing remediation, demolition, or maintenance work at any EPA facility could sign manifests without waiting for EPA staff availability.

How This Affects Site Remediation Work

CERCLA and RCRA Corrective Action Sites

Sites under federal oversight will see streamlined waste removal operations. Contractors no longer need to coordinate EPA personnel schedules with waste hauler pickup times. This eliminates project delays caused by manifest signing bottlenecks.

Federal Facility Cleanups

Non-Superfund federal facilities conducting environmental cleanup will benefit most from this change. Previously, these sites required EPA staff presence for all waste shipments, creating scheduling conflicts and project delays.

Contractor Responsibilities

Contractors signing manifests assume full regulatory responsibility for waste characterization accuracy and proper disposal facility selection. The manifest signature legally certifies that waste descriptions, quantities, and hazard classifications are correct.

What to Do Now

If you work on federal environmental projects:

  • Review current contracts: Check whether your existing EPA contracts include manifest signing authority provisions
  • Update procedures: Prepare staff training on proper manifest completion and signature requirements under RCRA regulations
  • Verify insurance coverage: Confirm your professional liability insurance covers manifest signing responsibilities
  • Track the rulemaking: Monitor the Federal Register for the final rule publication and effective date

The proposed rule streamlines federal site operations while maintaining regulatory compliance requirements. For detailed RCRA manifest requirements, see our hazardous waste guides.

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