New Electronic Manifest System being developed by EPA is expected to go live on June 30, 2018The EPA is establishing a national system, known as “e-Manifest,” for tracking hazardous waste shipments electronically. This system will modernize the nation’s current cradle-to-grave hazardous waste tracking process. US Waste Industries is devoted to providing its clients with superior client services as the specifics of the system and the nuances of navigating the system are revealed.
Benefits of the e-Manifest system include:
- It will save valuable time, resources, and dollars for industry and states.
- It creates a single hub for one-stop reporting of manifest data for use by EPA and states.
- It evolves the current system from a paper-intensive process to an electronic system.
- It is expected to save states and the waste industry $75-90 million annually.
- It provides more accurate and timely information on waste shipments.
- It provides rapid notification of discrepancies or other problems related to a specific shipment.
- It increases the effectiveness of compliance monitoring of waste shipments by regulators.
- And, potentially integrates manifest reporting with the RCRA biennial reporting process and other federal and state information systems.
Frequently Asked Questions (FAQs)
- Will US Waste Industries be participating in the EPA’s e-Manifest program?
Yes. We are currently developing a short- and long-term procedure to support our clients using the EPA’s e-Manifest system.
- Will the e-Manifest requirements become effective immediately on the same date in all states?
Yes. On the effective date, all hazardous waste manifests and manifest data will be managed by the EPA’s manifest processing center, rather than the individual states.
- What shipments will be required to comply with the e-Manifest program?
Any shipment required to use a hazardous waste manifest, including RCRA hazardous waste, TSCA (PCB) regulated waste, state RCRA hazardous waste, and special wastes for which a state requires the use of a hazardous waste manifest.
- How is the e-Manifest system expected to work?
When a generator logs into e-Manifest, he/she will initiate a new manifest and enter the information for the types and quantities of waste to be shipped. The shipment is scheduled with the destination facility. When the transporter picks up the waste, the driver logs into e-Manifest and electronically signs the manifest. The generator then electronically signs the manifest. A copy is printed to accompany the truck in accordance with DOT requirements. Upon delivery at the destination facility, the facility logs into e-Manifest, selects the manifest to receive the waste. When the receiving and review process is complete, the facility will accept the waste by signing and submitting the manifest in the e-Manifest program.
- Can a paper manifest still be used?
Yes. A shipment may be initiated using a new version of the paper hazardous waste manifest that includes new distribution instructions: submit the top copy of the manifest to the EPA Manifest Processing Center. The destination facility may mail the top copy to the Processing Center. Alternately, a PDF image of the manifest may be submitted. The EPA Processing Center will enter the manifest data into the e-Manifest system. A higher processing fee will apply. The receiving facility may also extract the data from the manifest and submit it to EPA as a data file. Shipments leaving a generator site on or prior to Friday, June 29, 2018 will be required to ship using the current 6-part manifest form. All shipments requiring a paper hazardous manifest after Friday, June 29, 2018 will be required to use the new 5-part manifest form. The new paper manifest form has been submitted to the EPA for approval and is waiting a reply from the EPA.
- How do I access the e-Manifest system?
The e-Manifest system is still in development. It will be located on EPA’s CDX Central Data Exchange website (See below) under the RCRA Info program. A user ID and password will need to be established. A test site is currently available for monitoring the development (See below). When EPA provides information on the opening of program registration, US Waste will provide further guidance on how to register for e-Manifest.
- What do I have to do to become authorized to electronically sign manifests?
The e-Manifest system is still in development. When the EPA provides information on the opening of program, US Waste will provide further guidance on how to apply for signatory authorization for e-Manifest.
- Will US Waste be able to prepare a manifest for a client on the e-Manifest system?
Yes, US Waste may draft an electronic manifest for a client. The EPA has indicated that they will be including a function that allows a generator to authorize an entity to create and/or sign a manifest on their behalf.
- Does the EPA charge a manifest processing fee?
Yes, to support the activities at the Manifest Processing Center. All fees are estimates and nothing is finalized. The highest fee is estimated to be $20 for a paper manifest requiring data entry, while a fully electronic manifest will have a fee of $4. US Waste will be working with clients and transporters to transition into the use of electronic manifests to minimize the processing fees. A destination facility (TSDF) will be billed monthly by the EPA based on the number of manifests submitted. We are expecting some fee by the TSDF to be passed to the generator based on the EPA fee structure and the type of manifest used for the shipment.
- Can corrections be made to a manifest after submittal to EPA?
Yes, corrections may be submitted any time that they are necessary.
- What is US Waste doing to prepare for the e-Manifest Program?
We are in communications with all destination facilities, including TSDFs, which will be receiving waste on an e-Manifest. We are consistently tracking the progress of the EPA and steering committee as the implementation date gets closer. We are analyzing our current business practices to determine the most effective way to handle paper manifests. We are providing guidance for our clients to help prepare them for the implementation of the e-Manifest program. We are analyzing our system to determine how it may be improved to assist clients creating e-Manifests. We are in communications with our paper manifest supplier regarding the new manifest format and the requirements regarding the use of paper.
- Where can I go find more information about e-Manifest?
We will be providing all our clients with updated information as soon as we receive it. But, if you are interested in learning more we provide a few sources below. The EPA site where you may test the new current test version of the e-Manifest system: https://epa.gov/e-manifest The e-Manifest page on the EPA website: https://www.epa.gov/e-manifest/learn-about-hazardous-waste-electronic-manifest-system-e-manifest Information from the EPA regarding fees: https://www.epa.gov/e-manifest/frequent-questions-about-final-rule-user-fees-electronic-hazardous-waste-manifest-system The EPA’s CDX Central Data Exchange website: https://cdx.epa.gov