In this edition of the Compliance Digest, we cover the June 30, 2018 launch by the EPA of the Hazardous Waste Electronic Manifest (e-Manifest) System.
What is it?
The EPA established a national system for tracking hazardous waste shipments electronically, known as “e-Manifest”, according to the Hazardous Waste Electronic Manifest Establishment Act, which became law in 2012.
e-Manifest aims to facilitate the electronic transmission of the manifest form, which accompanies shipments of hazardous waste from generators to waste brokers to transporters to treatment, storage and disposal facilities. e-Manifest affects any regulated waste shipped on a manifest, including:
- RCRA federal hazardous waste.
- Regulated PCB waste shipped on a manifest.
- State-regulated hazardous waste (if manifest is required by origination or destination state).
- Very Small Quantity Generator waste (if manifest required by state).
- Imported hazardous waste.
The e-Manifest system allows for three types of hazardous waste manifest creation options:
- Paper (generator, transporter and receiving facility all sign on paper).
- Hybrid (starts as paper manifest signed by the generator and then is signed electronically by the transporter and receiving facility).
- Electronic (created in e-Manifest and electronically signed by all entities listed on the manifest).
How are generators of hazardous waste affected?
Generators will have the option to create and submit manifests electronically in e-Manifest. If generators would like to use e-Manifest, they will need to obtain an EPA ID number and register with eManifest.
If generators do not create e-Manifest accounts for viewing hazardous waste manifests, they should make arrangements with their receiving facilities to obtain paper copies of completed manifests per recordkeeping requirements in 40 CFR part 262. The e-Manifest system will only supply electronic copies of completed manifests to registered generators with e-Manifest accounts.
Eventually, generators will need to register for e-Manifest if they wish to sign manifests electronically in the system, view manifest records in the system, or if they want the ability to submit post-receipt data corrections to the manifest.
Generators can use the EPA’s e-Manifest website to create electronic manifests or they can use the e-Manifest API to add e-Manifesting capabilities to their existing manifesting system.
What is next?
e-Manifest will launch across the U.S. tomorrow June 30, 2018. The existing 6-copy manifest form is being replaced with a new 5-copy form, which will be effective also on June 30, 2018. Generators may continue to use paper manifests after June 30, 2018, but the EPA highly encourages the use of e-Manifest. Generators will no longer be able to use paper manifests after five years.
Visit these webpages for more information:
- Frequent Questions About e-Manifest
- Countdown to the e-Manifest System Launch!
- Will e-Manifests Make Life Easier or Harder for EHS Pros?
- 12 Things You Should Know about EPA’s New E-Manifest Rule
- e-Manifest User Fee Rule Published
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