EPA launches the nation-wide electronic manifest system (e-Manifest) on June 30, 2018. The system is intended to modernize the nation’s cradle-to-grave hazardous waste tracking process. HTS Environmental is preparing for a smooth transition and full compliance with e-Manifest for its clients.
What is the e-Manifest System
The e-Manifest system establishes an electronic database run through EPA’s RCRA info website. The treatment facilities (TSDF) are responsible for submitting the manifest information to the EPA, for inclusion in this database. Any waste required to be put on a manifest (either by the laws of the originating state or the receiving state) must be submitted to the system. This means both RCRA and nonRCRA waste manifests will be included in the database. To offset the costs of developing and operating the e-Manifest system, a per manifest fee is charged to and paid by the TSDFs. Generators will not be responsible for submitting payments to the EPA or other agencies for waste manifests submitted to e-Manifest. However, treatment sites are passing these costs through to generators, either as a line item or as part of the disposal fees.
After the system launch, manifest users can choose one of three approaches when preparing manifest:
- Option 1: Fully electronic option (created in the database and electronically signed by the generator, transporter(s) and TSDF);
- Option 2: “Hybrid” half paper half electronic option; or
- Option 3: Users may continue to use paper manifests as they do now.
HTS will have the capability of preparing manifests using any of the three available options. However, we feel that it is in our generators’ best interest to adopt the system slowly to ensure minimum disruption of our client’s business operations. Additionally, many of the treatment sites are recommending that users continue to use paper manifest until further notice.
HTS will continue to collect waste manifested on paper forms, and the waste will be shipped in full compliance with all state and federal regulations. Once the EPA system proves to be working well, we will begin to transition to the “hybrid” option. This means HTS will create the manifest electronically, but still allow our generators to sign and retain a paper copy.
Major Changes Affecting Generators
The primary change for generators will be that after June 30th, disposal facilities will no longer send a paper receipt (also known as a “closed copy” of the manifest). This information will now be available for generators on EPA’s e-Manifest website[i] immediately after it is uploaded by the disposal facility. Generators will need to create an account to retrieve the information.
The EPA has posted Frequently Asked Questions about e-Manifesting where you can find more information, linked here[ii]. Please feel free to contact your Customer Service Representative or our Environmental Health & Safety Department if you have any questions. HTS will continue to update you as more information becomes available.
[i] RCRA Info Website: https://rcrainfo.epa.gov/rcrainfoprod/action/secured/login
[ii] EPA e-Manifest FAQ: https://www.epa.gov/e-manifest/frequent-questions-about-e-manifest