The U.S. EPA will launch the new electronic hazardous waste manifest (e-Manifest) system on June 30, 2018. All hazardous waste shipments from small and large quantity hazardous waste generators requiring a hazardous waste manifest must be submitted to the U.S. EPA for tracking through the e-Manifest system, beginning July 1, 2018. The new system will be used in place of hard copy manifests for the shipment of hazardous wastes for the purposes of compliance with federal and state environmental requirements.
The implementation of the e-Manifest will impact generators and transporters differently, based upon the process established by the receiving treatment, storage or disposal facility (TSDF). The receiving TSDF is responsible for submitting the e-Manifest information it receives to the U.S. EPA and paying for any e-Manifest processing fees due to the U.S. EPA. To ensure a smooth transition, the EPA is encouraging generators to review the e-Manifest options chosen by their TSDF.
TSDFs have four different e-Manifest submittal options. They can submit:
A paper manifest via mail, which requires hand input into the e-Manifest system;
A scanned pdf image of each paper manifest;
A data file of all manifests; or
An e-Manifest, originated in the e-Manifest system and electronically signed by the generator, transporter, and receiving TSDF (paperless manifest).
The per-manifest cost for each option varies based on the cost incurred by the U.S. EPA for manifest processing. Processing a paperless manifest is projected to cost $4, while processing the paper manifest is expected to cost $20. When creating an e-Manifest, the e-Manifest must still be printed and carried by the transporter to meet the U.S. DOT regulations. The EPA is working with DOT to potentially eliminate this requirement.
One significant change that generators may experience is not getting a paper manifest copy back from the receiving TSDF verifying receipt. Instead, generators may have to access the e-Manifest system to verify receipt by the TSDF. Registration is required to access the system.
Here are a few useful links to better understand these requirements:
CFR has nearly 30 years in assisting industry in achieving environmental compliance. Contact CFR with any questions you may have in transitioning to this new (hopefully streamlined) system.