EPA Eases Hazardous Waste Paperwork for Contractors Everywhere
Published Date: 4/8/2026
Proposed Rule
Summary
The EPA is updating its rules to let contractors sign hazardous waste forms at more sites, not just Superfund locations. This change means work can keep going even when EPA staff aren’t around, making cleanup faster and smoother. If you work with EPA contracts, get ready to follow this new rule once it’s finalized after June 8, 2026.
Analyzed Economic Effects
5 provisions identified: 4 benefits, 0 costs, 1 mixed.
Contractors Authorized to Sign Waste Manifests
The EPA proposes a clause that lets contractors sign EPA Form 8700-22 (Uniform Hazardous Waste Manifest) and non-hazardous waste shipping manifests at EPA worksites. This applies to both Superfund and non-Superfund EPA sites and is intended to let work continue when EPA staff are not present, reducing work stoppages and producing cost savings.
Signing Does Not Make Contractor a 'Generator'
The rule says a contractor who signs manifests after writing 'On behalf of the United States Environmental Protection Agency' in the signature block (including signature block #15 on EPA Form 8700-22) will not be considered a generator of hazardous or non-hazardous waste solely because they signed the manifest. The authorization only applies to sites assigned under the contract.
Clause May Be Inserted Into Subcontracts
The proposed clause explicitly allows insertion into subcontracts, so subcontractors performing transportation of hazardous or non-hazardous wastes at EPA worksites can also be authorized to sign manifests. This extends the operational effect to parties downstream on EPA cleanup contracts.
EPA Certifies No Significant Small-Entity Impact
Under the Regulatory Flexibility Act, EPA certifies this action will not have a significant economic impact on a substantial number of small entities and states the action will not impose requirements on small entities. EPA concluded there will be no net regulatory burden on directly regulated small entities.
EPA Will Use COI Reviews and Management Controls
EPA says it will implement management controls and address conflicts of interest (COI) during COI reviews for worksite cleanup procurements to prevent conflicts of interest and fraud when contractors are authorized to sign manifests. These reviews apply to procurement actions for cleanup work.
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