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Paper Manifest Sunset Rule: EPA Modification of the Hazardous Waste Manifest Regulations

March 09, 2026
The U.S. Environmental Protection Agency (EPA) is proposing regulatory amendments to the hazardous waste manifest regulations to establish a date for sunsetting use of paper manifests in favor of electronic manifests. Phasing out paper manifests would unlock the estimated $28.5 million annual savings through decreased burden to manifest users while also increasing human health and environmental protection through better tracking of hazardous waste and greater transparency for regulators and the public.
 
The proposed rule also introduces several conforming amendments to existing regulations. These include new registration requirements with the EPA's e-Manifest system for RCRA hazardous waste transporters, certain PCB waste generators, and PCB waste transporters. Additionally, the rule updates exception reporting requirements for very small quantity generators (VSQGs) managing hazardous waste from episodic events, as well as for healthcare facilities and reverse distributors handling hazardous waste pharmaceuticals. It also revises discrepancy reporting requirements for owners and operators of hazardous waste facilities operating under standardized permits.
 
Lastly, the proposed rule includes four technical corrections to the import and export requirements to correct EPA's mailing address, remove obsolete text, and correct a citation associated with manifest corrections for export shipments.
 
Read the proposed rule here.
 
Miami-Based Concrete Product Manufacturer Cited After Worker Suffers Fatal Injuries
 
The U.S. Department of Labor has cited a concrete manufacturer for exposing workers to hazards after an employee suffered fatal injuries after entering the unprotected area of a concrete block cubing machine in July 2025.
 
The department's Occupational Safety and Health Administration cited Adonel Concrete Corp. – operating as Adonel Block Manufacturing Corp. – with nine serious violations for inadequate machine guarding, and for failing to ensure lockout/tagout procedures were used, electrical panels were marked and the locking mechanism operational, implement an effective hearing conservation program for workers exposed to high-noise levels, and incorporate silica hazards into the company's hazard communication program.
 
OSHA assessed $58,604 in penalties.
 
Please check the OSHA establishment search page periodically for any changes in the inspection or penalty status.
 
Learn more about OSHA, including lockout and tagout practices and procedures that safeguard workers from the release of hazardous energy from machines. Employers may contact the agency for information about OSHA's compliance assistance resources and for free help on complying with OSHA standards.
 
OSHA Publishes Guidance on Hearing-Protector Fit Testing
 
A new OSHA safety and health information bulletin describes the importance of hearing-protector fit testing to ensure workers achieve appropriate noise reduction. Although not required in OSHA standards, hearing-protector fit testing “can be a valuable training tool for workers,” the agency notes.
 
Selecting the right hearing-protective device, or HPD, allows workers to hear important sounds such as safety warnings and other communications while blocking hazardous noise. Repeated exposures to noise above 85 dBA can contribute to hearing loss, cardiovascular disease, and workplace injuries, OSHA states. Individualized fit testing ensures workers can properly insert HPDs into their ear canals.
 
The guidance explains the two types of hearing protector fit-testing systems. Subjective systems require workers to respond to sounds played through headphones, while objective systems use microphones to test sounds inside and outside of an inserted earplug. Objective systems may be available only for certain brands of HPDs.
 
When implementing hearing-protector fit testing, OSHA recommends that employers consider whether the system meets ASA/ANSI 12.71-2018, Performance Criteria for Systems that Estimate the Attenuation of Passive Hearing Protectors for Individual Users. Other factors to consider include whether the device can test all HPDs in the workplace and monitor background noise, the length of time required to administer individual tests, and the way the system reports personal attenuation ratings. A PAR indicates whether a worker attained adequate noise reduction through HPDs. Some systems report PAR as either pass or fail, while others report a numerical value, which may be more useful for workplaces with variable noise levels, according to OSHA.
 
Florida Air Conditioning Contractor Cited for Exposing Workers to Hazards After Worker Fatality
 
The U.S. Department of Labor has cited a Florida plumbing, heating, and air conditioning contractor for exposing workers to struck-by hazards after an employee suffered a fatal injury at a Bal Harbor Shops worksite in August 2025.
 
The department’s Occupational Safety and Health Administration found that on Aug. 28, 2025, an Hyvac Inc. pipefitter installing a new air-conditioning system for a mall expansion construction project was fatally injured from a pressurized HVAC piping system.
 
The employer was cited with two serious violations for exposing workers to struck-by hazards by not verifying piping was free from stored pressure before employees performed work on the system and did not train workers to recognize and avoid hazards associated with removing HVAC end caps on pressurized pipping systems. OSHA proposed $28,135 in penalties.
 
Hyvac Inc. has 15 business days from receipt of the citations and penalties to comply, request an informal conference with OSHA’s area director, or contest the findings before the independent Occupational Safety and Health Review Commission. Penalties and citations may be adjusted throughout the course of the case process. Please check the OSHA establishment search page periodically for any changes in the inspection or penalty status.
 
Struck-by objects, part of OSHA’s construction “Focus Four,” are among the top four hazards causing many construction-related deaths. Employers may contact the agency for information about OSHA’s compliance assistance resources and for free help on complying with OSHA standards.
 
EPA Enforcement Action Brings Safety-Kleen Systems into Compliance at New Jersey Facility
 
U.S. Environmental Protection Agency (EPA) has reached a settlement with Safety-Kleen Systems, Inc., which has resulted in the company’s compliance with hazardous waste laws at its facility in Linden, New Jersey. EPA found several violations, including improper maintenance, equipment malfunctions and faulty storage, which violated regulations and posed a threat to human health and the environment. The settlement documents Safety-Kleen’s return to compliance and the company’s agreement to pay a penalty of $175,000. EPA worked with the company and Safety‑Kleen has repaired and upgraded equipment and improved labeling and handling procedures, which reduces the risk to workers and the community from facility operations.
 
“This settlement is just one example of EPA’s commitment to protect human health and the environment by ensuring that companies comply with hazardous waste regulations for tanks and containers,” said EPA Regional Administrator Michael Martucci. “At the fundamental level, properly handling hazardous waste helps us prevent sites needing future cleanup and upholds the safety of our communities.”
 
During a 2024 inspection, EPA found several problems at the Linden facility. The backup containment structures that are supposed to catch hazardous waste leaking from tanks or containers had cracks and gaps. Leaking pumps were not fixed on time, and some were not tagged for repair. Equipment was leaking and pipes were not properly sealed, which greatly increased the risk of releasing volatile organic compounds, harmful chemical vapors, into the air. The facility lacked proper labels on equipment and used the wrong types of containers to store waste.
 
Following the inspection, Safety-Kleen improved its hazardous waste management practices. This includes upgrading containment measures to prevent leaks and using the correct containers to transport waste. Additionally, Safety-Kleen held training sessions for maintenance staff and site leadership on compliance with the above-described requirements.
 
For more information about EPA’s enforcement program, visit https://www.epa.gov/enforcement.
 
CSB Report Describes Cause of 2024 Fatal Hydrogen Sulfide Gas Release
 
The release of more than 27,000 pounds of hydrogen sulfide gas at a refinery in Texas that resulted in the deaths of two contract workers in October 2024 was the result of “a completely preventable mistake,” says Steve Owens, chair of the Chemical Safety and Hazard Investigation Board. Owens’ remarks were released with CSB’s final investigation report into the incident, which occurred at the PEMEX Deer Park Refinery in Deer Park, Texas. According to the agency, the release was caused by the opening of incorrect equipment during maintenance activities. Contract workers mistakenly opened a flange on piping containing pressurized hydrogen sulfide instead of the flange they were supposed to open, which was approximately five feet away and clear of toxic gas.
 
“PEMEX Deer Park did not establish an effective method to clearly identify the correct equipment to open before authorizing opening the equipment,” CSB’s report states. “Due to the lack of a reliable method to identify the intended equipment, the [contract] workers searched for unlocked flange-locking devices, which they commonly observed elsewhere in the refinery.”
 
CSB also found safety issues related to work permitting and hazard control, turnaround contractor management, and conduct of operations. According to the agency, the incident was made more severe because PEMEX Deer Park did not “adequately evaluate the hazard posed by opening equipment within an active unit that was adjacent to a unit undergoing a turnaround where many contractors were exposed to the hydrogen sulfide release.”
 
Refinery emergency responders took nearly an hour to reassemble the leaking flange and stop the release. In addition to the two workers who died, 13 others were transported to local medical facilities, and dozens more were treated at the scene. Two cities neighboring the refinery issued shelter-in-place orders.
 
The new report contains several safety recommendations for both PEMEX Deer Park and the American Society of Mechanical Engineers (ASME), a nonprofit professional organization whose mission in part includes developing codes and standards for the engineering community. One of CSB’s recommendations to PEMEX Deer Park is to label all piping in accordance with the standard ANSI/ASME A13.1, Scheme for the Identification of Piping Systems. The agency urges ASME to develop written guidelines for marking equipment for opening.
 
“The guidelines should define a standard practice for equipment marking that includes clear identifiers of the area to be opened and means to remove the markings at the conclusion of the work,” CSB explains.
 
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Trivia Question of the Week
Under the United States Environmental Protection Agency hazardous waste manifest system, what is the primary purpose of the Uniform Hazardous Waste Manifest required under the Resource Conservation and Recovery Act (RCRA)?