PROBLEM: The manifest system only proves the waste arrived if the signed copy comes back. When it does not, the generator must act: large quantity generators contact the transporter and receiving facility after 35 days and file an exception report after 45 days; small quantity generators file an exception report after 60 days. Since December 1, 2025 those exception reports must be filed electronically through EPA's e-Manifest system — mailed paper is no longer accepted. A generator that misses the window has no record that it ever chased the missing shipment.
SOLUTION: A manifest exception report timeliness register: every shipment watched from pickup, with the 35-day contact and 45/60-day exception-report deadlines counted down by generator class, and any missing signed copy escalated automatically — so a lost shipment is chased on the regulatory clock, not discovered at the next inspection.
EVIDENCE BASIS: DOCUMENTED — 35-day contact / 45-day exception report (LQG) and 60-day exception report (SQG); electronic exception reports required from December 1, 2025; sources: safety.mlsascp.com; legalclarity.org; NY DEC.
| Idea priority | Low |
| Needed By | Not sure -- Just thought it was cool |
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