What is a Manifest?
  • The Uniform Hazardous Waste Manifest is the shipping document that travels with hazardous waste from the point of generation, through transportation, to the final treatment, storage, and disposal facility (TSDF).
  • A hazardous waste manifest must accompany most hazardous waste that is shipped off site.
  • Currently, each party in the chain of shipping, including the generator, signs and keeps one of the manifest copies, with a final copy returned to the generator, thus, creating a “cradle-to-grave” tracking of the hazardous waste.
What is E-Manifest
  • U.S. EPA is establishing a national system for tracking hazardous waste shipments electronically. This system, known as “e-Manifest,” will modernize the nation’s cradle-to-grave hazardous waste tracking process while saving valuable time, resources, and dollars for industry and states.
  • U.S. EPA is establishing the e-Manifest system according to the Hazardous Waste Electronic Manifest Establishment Act, enacted into law on October 5, 2012. The “e-Manifest Act” authorizes U.S. EPA to implement a national electronic manifest system and required that the costs of developing and operating the new e-Manifest system be recovered from user fees charged to those who use hazardous waste manifests to track off-site shipments of their wastes.
 Benefits of e-Manifest
  • Cost Savings
  • Creation of a single hub for one-stop reporting of manifest data to U.S. EPA and states
  • Accurate and more timely information on waste shipments
  • Increased legibility of information on waste shipments
  • Rapid notification of discrepancies or other problems related to a particular shipment
  • Increased effectiveness of monitoring of waste shipments by regulators
  • The potential for integrating manifest reporting with Resource Conservation and Recovery Act (RCRA) biennial reporting process and other federal and state information systems
Data Elements of e-Manifest:
  • The basic regulations or instructions for completing the electronic manifest will not be materially different from today’s regulations or instructions for completing a paper manifest.
  • The data elements will remain the same.
  • The only differences involve completing the electronic form and signing it electronically.
  • It is a software, not a fillable form.
  • The e-Manifest will include state hazardous waste codes in addition to the federal hazardous waste codes.
How will e-Manifesting impact DOT Requirements for shipping papers?
  • DOT is proposing to change its rules to allow for electronic signature of the manifest, however, a printed copy of the manifest bearing electronic signature will be required.
Proposed Rule (j) Electronic manifests that are obtained, completed, and transmitted in accordance with 40 CFR 262.20(a)(3), and used in accordance with § 262.24 in lieu of EPA Forms 8700-22 and 8700-22A are the legal equivalent of paper manifest forms bearing handwritten signatures, and satisfy for all purposes any requirements in these regulations to obtain, complete, sign, provide, use, or retain a manifest. Electronic signatures in conformance with 40 CFR 262.25 are therefore acceptable in lieu of handwritten signatures required by paragraphs (c) and (d) of this section provided one printed copy of the electronic manifest bearing the electronic signature is provided to the initial transporter as required by 40 CFR 262.24(d). Paper Manifests:
  • Paper manifests may still be used
    • Generators may still use paper manifests for 3-5 years, but will be charged higher costs
    • Receiving facility may still use paper manifests for up to 3 years but will be charged higher costs
  • EPA institutes the phase-out of paper manifests after 3 years
  • During phase-out, generator may still use the paper manifest but receiving facility will need to transfer data in digital format to EPA
  • Generators choosing to still use paper copies will need to make arrangements with their receiving facility on obtaining a paper copy of the manifest
  • EPA is changing the current 6-part form to a 5-part form, resulting from the replacement of two copies that were previously earmarked for distribution to states with one copy to be submitted to e-Manifest system.
  • EPA anticipated using the new form beginning June 30, 2018, however, the form is not yet available.
 VSQGs
  • Very Small Quantity Generators (VSQGs) have not been required federally to use manifests for transporting wastes
  • VSQGs choosing to use the e-Manifest system will have to register
  • Over time, it is likely TSDFs will only accept e-Manifest from VSQGs
  • Timing:
  • e-Manifest is anticipated to launch June 30, 2018.
  • However, the new 5 part paper manifest is not yet available and there have been comments submitted on the electronic system during testing.
  • Keep checking with the EPA on the status.
————————————————————————————————— Cassie Lee is an Account Manager and Business Development Professional with over a decade of experience in environmental consulting.  You can reach her at clee@corner-enviro.com or 317-983-1719 with any questions or for assistance on waste reporting.  

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