Memphis sits where three states meet, and each state runs its own rules for pumping and hauling portable toilet waste. This guide names the agency for each state, the requirement it sets for the person doing the pumping, and what remains unverified, so you know which questions to put to a provider before a unit arrives.
Key takeaways
- Tennessee requires an annual permit from the state commissioner for anyone in the business of removing and disposing of septage from portable toilets.
- Mississippi certifies septage pumpers through the state health department, using an application that asks for a disposal letter and a vehicle inspection.
- Arkansas defines a septic tank cleaner to include anyone who pumps portable toilets, and requires that the waste go to a permitted treatment facility.
- The rules follow the state where the unit sits, not the state where the office is, so a job in West Memphis is judged under Arkansas rules.
- A Shelby County pumper permit, a Mississippi fee and an Arkansas application form were not confirmed for this page, and none is stated here.
Why do three sets of rules apply here?
Memphis sits where Tennessee, Mississippi and Arkansas meet, and the service radius reaches into a Mississippi county and across the river into Arkansas.
Portable toilet waste is septage, and each state treats the hauling of septage as a regulated activity. The rule that applies is set by the state where the unit is pumped and the waste is taken, not by the state where the provider answers its telephone. A call answered in Memphis for a job in Southaven is a Mississippi job for regulatory purposes.
That is why this page keeps the three states apart. A Tennessee rule does not cover a job in Crittenden County, Arkansas, and an Arkansas rule does not cover DeSoto County, Mississippi. Anyone who says one set of rules covers the whole area is simplifying, and that simplification matters most when an inspector asks where the waste went.
Local health departments and city governments also have roles of their own. This page does not state what any of them requires for a pumper, and where a local question is open it is listed in the last section as something to ask.
What does Tennessee require?
Tennessee Rule 0400-48-01-.20 requires an annual permit from the Commissioner of the Tennessee Department of Environment and Conservation for anyone in the business of removing and disposing of septage from portable toilets.
The rule covers domestic septage taken from septic tanks, holding tanks, portable toilets and similar facilities. A business doing that work must hold an annual permit, and the Commissioner may refuse one to an applicant whose earlier permit was denied, suspended or revoked. The rule text this page relies on was current to 24 September 2024, so check the state's own text before relying on it in a dispute.
The state's Division of Water Resources is the place to check a provider's status. A caller can ask a provider for its permit number and then confirm it with the division. That check takes a few minutes and is worth doing before a long placement, a multi-week rental or a construction contract where the waste volumes add up.
What this page does not claim: it has not found a Tennessee credential specific to renting portable toilets, and it does not say that the Shelby County health department issues its own pumper permit. Whether a county or city adds a requirement for a particular event or site is a question to put to that local office directly. An answer of 'I am not sure' from a provider should send you to the state division, not end the conversation.
What does Mississippi require?
The Mississippi State Department of Health certifies septage pumpers, and the application asks for a letter of disposal and a vehicle inspection.
The state health department runs the certification for septage pumpers under state law, cited in the application as Mississippi Code section 41-67-39 and the department's own regulations. The application this page reviewed was a 2018 form, so the paperwork a provider uses today may differ. That form asked for a letter of disposal from a facility permitted by the Mississippi Department of Environmental Quality and for a vehicle inspection.
Fees and insurance amounts on that form are dated, and this page prints none of them. A Mississippi caller can ask the provider for its certification and for the disposal letter that goes with the job, which tells you where the waste was taken, not only who took it.
There is also a draft state chapter on non-waterborne systems, which said a county health department may approve portable toilets for temporary or transient locations. That draft was labelled proposed, and whether it is in force has not been confirmed. Do not assume a county approval is needed, and do not assume it is not. The DeSoto County health department and the state onsite wastewater office are the places to ask. Portable toilets in Southaven, Horn Lake and Walls covers the DeSoto County jobs in more detail.
What does Arkansas require?
The Arkansas Department of Health's rules for septic tank cleaners, effective 25 March 2024, cover anyone who pumps portable toilets or hauls septage in Arkansas.
The rules define a septic tank cleaner to include anyone who pumps portable toilets or hauls septage in the state. That definition matters because a provider doing a single West Memphis job is in scope even if most of its work is in Tennessee. The state's onsite wastewater programme administers the rules. The application form and fee were not found for this page.
Arkansas also sets a disposal rule that is easy to miss: waste from portable toilets must go to a permitted sewage treatment facility, and it may not be land-applied. A caller can ask where the waste is taken. A provider that cannot name the receiving facility has not answered the question. Renting across the river in West Memphis and Marion takes the Arkansas logistics further.
What should you ask a provider?
Four questions cover most of the regulatory ground, and a provider who can answer them plainly is one you can check.
Ask which state's credential covers the job you are booking. For a unit in Southaven that is Mississippi's; for a unit in West Memphis it is Arkansas's. Ask for the certificate or permit number and check it with the agency that issued it.
Ask where the waste is taken, and for the name of the receiving facility. Ask how often the unit is pumped and whether the waste is hauled in the same vehicle that services other units. A provider that answers those questions without a pause has usually thought about them before the phone rang.
The table sets the three states side by side, with the agency to ask and the document to request for each one.
| State and area | Who covers pumping | What to ask the provider |
|---|---|---|
| Tennessee (Shelby County and the Memphis neighbourhoods) | Tennessee Department of Environment and Conservation, annual permit under Rule 0400-48-01-.20 | Permit status, checked with the state's Division of Water Resources |
| Mississippi (DeSoto County: Southaven, Horn Lake, Walls) | Mississippi State Department of Health, septage pumper certification | Certification, and the disposal letter for the job |
| Arkansas (Crittenden County: West Memphis, Marion) | Arkansas Department of Health, septic tank cleaner rules | The permitted facility that receives the waste |
What is still unverified?
Several local and state details were not confirmed, and this page would rather say so than fill the gap.
Not confirmed: whether Shelby County issues its own pumper permit in addition to the state's; whether a Mississippi county approves a portable toilet placement under a rule now in force; the Arkansas application form and fee; and any current Mississippi fee or insurance amount. Each is left out rather than estimated.
Treat this page as a map of which agency to ask, not as the final word on any single job. Before a large contract, ask the provider for its written regulatory position and check it with the agency named here. The agency's answer is the one that counts, and a dated written answer from the agency is worth more than a confident sentence from a sales call.
Who is responsible for the pumping?
The state rule sits on the person doing the pumping. The owner of the site or the event still has a stake in who that is.
The credential obligation sits with the provider, not with the person who rents the unit. That is the plain way to put it, and this site has not verified how each state would apply the rule to every case. What a renter controls is who they hire and what they ask. A renter who books a provider without knowing which state's rule covers the job has skipped the one question that is easiest to ask.
For event organisers, the same logic applies to the site. Ask the provider to confirm the disposal route in writing, and keep that confirmation with your event file. It costs nothing to ask, and it is the paperwork that matters if a county, city or state inspector asks where a unit's waste went after the event.
Frequently asked questions
Does Tennessee require a permit for a portable toilet rental?
Tennessee's rule that this page reviewed requires an annual permit from the state commissioner for anyone in the business of removing and disposing of septage from portable toilets. It does not name a separate rental credential, and none was found. Check a provider's permit status with the state division.
Is a Mississippi certification the same as a Tennessee permit?
No. Mississippi certifies septage pumpers through the state health department, and Tennessee issues an annual permit through the environment department. Each is issued by a different agency under a different rule, so a provider working across the state line needs to satisfy both for the job in question.
Do Arkansas rules cover a unit in West Memphis even if the provider is based in Memphis?
Yes. The Arkansas rules define a septic tank cleaner to include anyone who pumps portable toilets or hauls septage in the state, and the job sits in Arkansas. Ask which permitted facility receives the waste.
Who should I call first if I am unsure?
Start with the agency for the state where the unit sits. For Tennessee that is the environment department's water resources division, for Mississippi the state health department's onsite wastewater office or the DeSoto County health department, and for Arkansas the Department of Health's onsite wastewater programme.
Sources
This guide is general information for Shelby County homeowners, not a substitute for an on-site inspection. Prices are estimates. See our disclaimer.