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On November 22, 2019, the Illinois Pollution Control Board (IPCB) proposed in Volume 43, Issue 47 of the Illinois Register to make amendments to the manifest requirements for transporting special waste.

In the current regulations, the IPCB requires any person who delivers special waste to a permitted special waste transporter to complete a Uniform Hazardous Waste Manifest (UHWM) to accompany the waste during transport. The proposed amendments would require the U.S. Environmental Protection Agency's (EPA) prescribed UHWM only for the transport of hazardous waste.

For nonhazardous special waste, there will be new forms prescribed by the Illinois Environmental Protection Agency. The goal is to allow transporters of nonhazardous special waste to use functionally identical manifests to track such waste while avoiding the costs and burdens associated with EPA's e-Manifest system. The IPCB will accept written public comments on the proposed change until January 6, 2020.

For additional information on this topic or other Illinois regulatory issues, please contact Trinity's Chicago office at (630) 495-1470, or the St. Louis office at (636) 530-4600.