45-day inquiry clock
If a signed manifest copy is not received within 45 days, the generator must contact the TSDF and document the inquiry. Our engine tracks every manifest and auto-generates the inquiry letter.
The most rigorous RCRA manifest-compliance engine a generator can use.
ManifestClear assembles a documentation-complete compliance file — every manifest tracked, every 45/60-day clock monitored, every Exception Report drafted and filed through e-Manifest, every waste determination documented — checked against the letter of 40 CFR Parts 262 and 268 before a credentialed specialist releases it.
Every clock under 40 CFR 262.42Five statutory manifest elements, gate-checkede-Manifest · RCRAInfo · SDS · generator knowledgeCredentialed specialist release on every file5-business-day SLA
Why compliance fails
A single missed clock can trigger $93,058 per day in penalties.
A hazardous-waste generator's compliance is only as strong as its manifest follow-up. Miss the 45-day inquiry deadline, fail to file an Exception Report within 60 days, skip a written waste determination for any waste stream, or lose track of a signed manifest — and the generator faces civil penalties of up to $93,058 per day, per violation, plus criminal exposure for knowing violations.
Most generators run this by hand, from memory, with an overworked EHS generalist chasing signed copies by email. The statute has not been read end-to-end since the last inspection. That is exactly where compliance gaps hide.
ManifestClear exists to close that gap with a single, exhaustive standard applied identically to every manifest.
#1
most-cited RCRA violation: failure to make a proper hazardous-waste determination
The benchmark
Measured against the letter of the regulation — subsection by subsection.
We do not summarize the law and hope. Every file is scored against a versioned rule pack tied to the exact text of 40 CFR Parts 262 and 268. These are the provisions each file is held to.
60-day Exception Report
If no signed copy is received within 60 days, the generator must file an Exception Report with EPA. We draft and file it through e-Manifest before the deadline.
Written waste determination
Every waste stream must have a documented hazardous-waste determination (generator knowledge or analysis). We build and maintain a defensible determination for each stream.
Manifest completeness
Every manifest must include generator info, EPA ID, waste codes, container details, and signatures. We verify each element against the regulation.
Biennial report readiness
Generators must submit a biennial report by March 1 of even-numbered years. We maintain a data package ready for assembly.
Land disposal restriction (LDR) notices
For restricted wastes, LDR notices must accompany the manifest. We flag missing or incomplete LDR documentation.
How compliance is built
Intake to specialist release, with deterministic gates the AI cannot overrule.
AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A credentialed hazardous-materials professional signs every release. That order is never reversed.
01
Compliance Gap Scan
Upload your manifest stream (e-Manifest account or hauler PDFs) and waste stream list. We return a free compliance read: which clocks are running, which determinations are missing, and which Exception Reports are due.
02
Evidence & data ingestion
As your authorized clerical agent, we pull manifests from e-Manifest/RCRAInfo, collect SDSs, and build a waste-stream register with generator knowledge documentation.
03
Grounded drafting
Exception Reports, inquiry letters, and waste determinations are drafted from your validated data and the 40 CFR rule pack into field-locked templates — no legal opinions, no invented facts.
04
Deterministic completeness gates
Clocks are verified against the manifest date; waste codes are reconciled to the regulation; the determination checklist is resolved; any failure blocks release.
05
Specialist release
A credentialed hazardous-materials professional reviews the exception queue and signs the release. High-volume or complex waste streams route to senior review first.
06
Delivery
You receive the compliance file: manifest register, clock log, Exception Reports (filed), waste determinations, inquiry letters, and a monthly inspection-ready binder — ready for your records.
The bar we hold
Rigor you can measure.
100%
Specialist-released
No file ships without a credentialed human signature.
5 days
Standard SLA
From complete intake to released compliance file.
<1%
Critical-defect target
Tracked against a gold-standard compliance library.
4
Data sources
e-Manifest · RCRAInfo · SDS · generator knowledge, every applicable file.
Why ManifestClear
Built to be the most thorough option a generator has.
Documentation-complete, by design
The deliverable is completeness itself — every clock tracked, every determination documented, every Exception Report filed or explicitly exception-coded. Nothing is left implicit.
Deterministic, not vibes
The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a regulatory requirement.
In its lane, on purpose
We prepare documentation and run searches as your clerical agent. We never give legal advice, sign as the generator, or make operational decisions.
Engagement
Flat fee, per facility per month plus per-unit. No contingency, ever.
Simple, predictable, and aligned with a compliance standard — not a cut of any penalty avoidance.
- A free Compliance Gap Scan before you commit — see exactly what is missing.
- One flat fee per facility per month (includes manifest tracking and clock monitoring) plus per-unit fees for Exception Reports filed and waste determinations documented.
- Optional fixed-fee senior review for complex waste streams or high-volume facilities.
- Optional Biennial Report Assembly add-on for the March-of-even-years submission.
FAQ
Questions, answered precisely.
Is ManifestClear a law firm?
No. ManifestClear, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Attorney review is available and recommended for complex compliance matters.
Do you sign manifests or act as the generator?
Never. ManifestClear is not the generator and does not sign manifests or certifications. The generator remains the legal signatory and responsible party for all compliance obligations.
What makes a file 'complete'?
Completeness is defined by the regulation: every manifest tracked, the 45/60-day clocks verified, Exception Reports filed or exception-coded, waste determinations documented, and LDR notices flagged. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is five business days from complete intake to a specialist-released compliance file. The free Gap Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
A flat fee per facility per month, plus per-unit fees for Exception Reports and waste determinations. No contingency and no percentage of any penalty avoidance.
See what's missing before it costs you a penalty.
Start with a free Compliance Gap Scan. Send your manifest stream and waste stream list and we'll return a compliance read against every clock and determination requirement of 40 CFR Parts 262 and 268.
Documentation-completeness service · not legal advice · the generator remains the legal signatory.