AS WE ALL KNOW, DATA IS MORE than just information; it’s insight, too. And data collected from the hazardous waste generators via the U.S. Environmental Protection Agency’s newly released e-Manifest system is no exception to this rule.

The e-Manifest will give the EPA greater insight into the trends of quantities, types and generators of hazardous waste. What further application this data will reveal to the EPA remains to be seen, but the agency does intend to use the data to help lessen the burden of those organizations that submit a bienial report.

A Little Background

On June 30, 2018, the EPA launched the new e-Manifest software application designed to allow hazardous waste handlers to manage and track hazardous waste manifests through an electronic record rather than a multicopy paper record. This e-Manifest application exists as a module of the EPA’s existing RCRAInfo web-based platform. RCRAInfo is the EPA’s existing information system that collects information on hazardous waste sites, such as generator registration and the amount of waste generated, and holds myRCRAid and Biennial Report submission and e-Manifest applications.

The EPA’s initial proposal to transition from paper-based to electronic reporting occurred in May 2001, but the establishment of the e-Manifest system didn’t take place until the Hazardous Waste Electronic Waste Manifest Establishment Act was enacted into law on Oct. 5, 2012. Also known as the “e-Manifest Act,” it authorizes the EPA to implement a national electronic manifest system and requires that the costs of developing and operating the new e-Manifest system will be recovered from user fees charged to those who use hazardous waste manifests to track off-site shipments of their wastes.

Time to Register

If you are wondering if this new system applies to you as a hazardous waste generator, the answer is yes, definitely and absolutely. Whether you are a generator, transporter or a receiving facility, you will need to register and create an account with e-Manifest, so your manifests can be properly tracked and managed.

Hazardous waste generators will need to log into the system, at a minimum, to receive the return copies of a manifest. Receiving facilities are no longer obligated to send a return copy of a manifest by mail since all tracking can be done in the e-Manifest system. Transporters might need to electronically sign a manifest if the generator is using a fully electronic manifest but, at any time, can print a paper copy of an electronic manifest to fulfill the shipping paper requirement of the hazardous waste shipment.

Most of the burden of e-Manifest falls on the receiving facility or Treatment, Storage and Disposal Facility (TSDF). Receiving facilities have more responsibility than the generators and transporters because they are receiving the bill from the federal government for the use of the e-manifest system based on how many manifests they process. The user fee for each manifest is based on how the manifest was submitted and the corresponding costs to to process the data. The EPA will continue to evaluate the user fee in accordance with its user-fee calculation methodology.

Currently, it appears that the most popular way to use the e-Manifest system is through the use of a “hybrid manifest.” By that we mean where the manifest starts out as a paper copy; the generator keeps the initial signed copy; the paper copy is maintained throughout transport;, and, once the manifest reaches the receiving facility, it is entered into the e-Manifest system via the user interface using manual entry or through the upload of an image and a data file. The EPA and the e-Manifest development team have made sure the system is designed to allow many different kinds of TSDFs to be able to interface with the system. Although the number of completely electronic manifests is quite low, less than 1% of submissions are fully electronic and almost 75% of the completed manifest submissions are sent using an image upload of the signed manifest along with the data file.

Sphera is assisting our customers with the navigation of this new regulation and helping them find the most efficient solution for their business practices. Our customers’ waste contracts typically require the contractor to provide the hazardous waste manifest. If the hazardous waste contractor is still presenting you paper manifests, chances are, it is costing you in the long run. Ask questions and encourage them to use the e-Manifest system as it is now the final version of truth of any hazardous waste manifest, and it is also the best way to reduce user fees in the future.

Sarah Henderson

Sarah Henderson

Sarah Henderson is a Certified Hazardous Materials Manager specializing in hazardous materials/hazardous waste management and OSHA HAZCOM compliance. She currently works as an Environment, Health, Safety & Sustainability professional and customer success manager with Sphera supporting military installations and the Defense Logistics Agency with hazmat management practices, environmental compliance and sustainability opportunities. Henderson has more than 20 years of EHS&S experience and is currently serving on the board of directors of the Alliance of Hazardous Materials Professionals.

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