Information on EPA’s e-Manifest System for Hazardous Waste

To best serve our customers, we would like to take this opportunity to share information about a program and regulations that affect hazardous waste generators, transporters, and receiving facilities. In June of 2018, the EPA rolled out its new e-Manifest System. The system is intended to improve and phase out the paper-intensive Uniform Hazardous Waste Manifest form system.

Gannon & Scott is authorized to accept hazardous wastes that contain an economically sufficient amount of precious metals under the exemption 40 CFR 266 subpart F. This exemption includes the regulatory requirements of the general manifesting rules.

Gannon & Scott’s EHS Managers monitor progress and keep current with all available information surrounding the e-Manifest system.

If this information is something you are not directly responsible for, please share this with your company’s EHS professional. If you have any questions, please feel free to contact our offices at 800-556-7296 or hello@gannon-scott.com.

To find out more about the new e-Manifest System, please read the below highlights and frequently asked questions (FAQs).

EPA.gov

More About the Hazardous Waste Electronic Manifest System (e-Manifest)

EPA has established a national system for tracking hazardous waste shipments electronically. This system, known as “e-Manifest,” modernizes the nation’s cradle-to-grave hazardous waste tracking process while saving valuable time, resources, and dollars for industry and states. EPA launched the e-Manifest system in June 2018.

By enabling the transition from a paper-intensive process to an electronic system, the EPA estimates e-Manifest will ultimately reduce the burden associated with preparing to ship manifests by between 300,000 and 700,000 hours, saving state and industry users $75-$90M annually.

Benefits of the e-Manifest system include:

Cost savings;
Accurate and more timely information on waste shipments;
Rapid notification of discrepancies or other problems related to a particular shipment;
Creation of a single hub for one-stop reporting of manifest data for use by EPA and states;
Increased effectiveness of compliance monitoring of waste shipments by regulators; and
The potential for integrating manifest reporting with Resource Conservation and Recovery Act (RCRA) biennial reporting process and other federal and state information systems.

The Hazardous Waste Electronic Manifest Establishment Act

The Hazardous Waste Electronic Manifest Establishment Act authorizes EPA to establish a national e-manifest system to track hazardous waste shipments. The Act gives EPA authority to adopt regulations that 1) accept electronic-manifests in addition to the existing paper manifests and 2) set up user fees to offset the costs of developing and operating the e-Manifest system.

Key features of the Hazardous Waste Electronic Manifest Establishment Act are:

e-Manifest extends to all federally and state-regulated wastes requiring manifests
EPA encourages the use of electronic submittals, though the statute allows the optional use of paper manifests. and authorizes the central collection of data from electronic and paper manifests
EPA is authorized to collect reasonable user fees for all system-related costs, including development and maintenance
EPA must conduct annual Inspector General audits and submit biennial reports to Congress
EPA must establish a uniform effective date in all states for e-Manifest and must implement e-Manifest until states are authorized

e-Manifest FAQ’s

Is Gannon & Scott planning on participating in the e-Manifest program?

Yes, Gannon & Scott as a receiving facility is required to participate. Our EHS Managers are keeping current with the information and are ready to support internal and external customers.

Did the e-Manifest requirements become effective immediately on the same date in all states?

Yes. On the effective date, June 30, 2018, all hazardous waste manifests and manifest data are managed by the EPA’s manifest processing center, rather than the individual states.

Can a paper manifest still be used?

Yes. A shipment may be initiated using a new version of the paper hazardous waste manifest that includes new distribution instructions: submit the top copy of the manifest to the EPA Manifest Processing Center. The destination facility may mail the top copy to the Processing Center. Alternately, a PDF image of the manifest may be submitted. The EPA Processing Center will enter the manifest data into the e-Manifest system. A higher processing fee will apply. The receiving facility may also extract the data from the manifest and submit it to EPA as a data file.

My waste contains recoverable amounts of precious metals, and I ship under the exemption 40 CFR 266 subpart F. Do I have to use the new e-Manifest?

Under the precious metal exemption generators, transporters and receiving facilities are required to follow the general manifesting requirements. Proper use of paper manifests or e-Manifests satisfies the requirement.

Gannon & Scott currently prepares hazardous waste manifests for materials we ship to them for reclaim. With the e-Manifest system, will Gannon & Scott continue to support this and prepare manifests for customers?

Yes, Gannon & Scott may prepare an e-Manifest for a customer. In public comment, EPA acknowledged that it would be possible for a generator to authorize a contractor to create a manifest “on their behalf”. However, authority to sign manifests is more limited. Manifests prepared by others for a generator customer can be signed by the generator, or by a person that can certify that the waste materials have been properly described and the shipment is in proper condition for transportation.

How is the e-Manifest system going to work?

The e-Manifest system is a module component of the existing Resource Conservation and Recovery Act Information System (RCRAInfo). The e-Manifest provides the stakeholders listed below with the following functions:

Generators and transporters of waste shipped on a manifest: Generators and transporters can create, edit and sign manifests and retrieve copies and status information on manifests. Transporters can also locate manifests created by generators that indicate they are the intended transporter.
Receiving facilities: Facilities receiving waste shipped on a manifest can sign manifests when the waste is received, submit the manifests to EPA, make corrections to submitted manifests, and retrieve copies of manifests submitted within the past three years.
States and Tribes: State and tribal government users can retrieve copies and status information on any manifests associated with entities in their state.
General Public: e-Manifest data is accessible to the general public through the system’s public-facing website.

E-Manifest Tutorial Video

Will the e-Manifest be accessible on mobile devices, like a tablet or smartphone?

Yes, e-Manifest is accessible on mobile devices.

Will EPA charge a user fee for e-Manifests?

Yes, EPA is still working on a fee schedule. One plan that the Agency has outlined is a $20 fee for each paper manifest and $4 for each electronic manifest. The purpose of the fees are intended to support the activities at the Manifest Processing Center, e-Manifest development and O&M costs. The proposed schedule is also structured to incentivize participation in the e-Manifest system. Since managing costs are an important part of any business Gannon & Scott will be prepared to assist and support customers in adopting the e-Manifest system.

Will the e-Manifest system collect manifests for wastes that are not regulated as hazardous by the EPA but regulated as hazardous by a state?

Yes, the e-Manifest system collects manifests for all wastes shipped on a manifest, whether regulated as hazardous waste by EPA or a state.

Will the data elements currently applicable to paper manifests change with the use of electronic manifests?

No, the basic regulations or instructions for completing an electronic manifest are not materially different from today's regulations or instructions for completing a paper manifest. The data elements will remain the same, and the only differences involve completing an electronic form and signing the form electronically. EPA found that electronic manifests are the legal equivalent to paper manifests in all relevant respects.

Additional Background and History of e-Manifest

EPA’s initial proposal to transition from paper-based to electronic-based reporting occurred in May 2001. After receiving numerous comments, conducting several national stakeholder meetings, and proposing supplemental notices on the subject, the Agency was persuaded that electronic manifesting would produce numerous benefits. These benefits include cost savings, better, and more timely information on waste shipments, rapid notification of discrepancies or other problems related to a particular shipment, the creation of a single hub for one-stop reporting of manifest data to EPA and states, increased effectiveness of compliance monitoring of waste shipments by regulators, and the potential for integrating manifest reporting with the Resource Conservation and Recovery Act (RCRA) biennial reporting process and other federal and state information systems.