01
Manifest data is the whole report
If the manifests are complete and consistent, the summary follows. If they are not, the report becomes a reconstruction exercise. Where KODA moves the material, that record is maintained as the year goes rather than gathered at the end of it.
02
Codes drift between sites
The same material classified one way at one plant and another way at a second plant produces totals that cannot be compared and a report that invites a question. Catching that is part of the work.
03
Texas has its own filing
The Annual Waste Summary is a state requirement separate from the federal biennial report, and registered generators file one whether or not they had reportable waste. Filing nothing is not the same as filing a nil return.
04
The biennial report is every other year
It covers odd-numbered years and is due the following March, which means it is easy to lose track of. It applies to large quantity generators and to facilities that treat, store or dispose.