By Thomas E. Long, Associate Environmental Specialist
A PDF of this article can be found here.
The U.S. Environmental Protection Agency (EPA) debuted its national hazardous waste tracking system, the e-Manifest program, in all states on June 30, 2018. The e-Manifest program offers new manifesting and tracking options for hazardous waste generators, transporters, receivers, and brokers of hazardous wastes. The e-Manifest program was designed to work with the Resource Conservation and Recovery Act (RCRA) program to track wastes from cradle to grave.
How it Works
All designated disposal facilities will now submit all manifests, both paper and electronic, to EPA once a manifest is signed by all parties (i.e., hazardous waste generator, transporter, and designated disposal facility). EPA then uploads non-electronic manifests to the e-Manifest system, where all manifests will be retained indefinitely. Public access to manifests generally will be available 90 days after manifests are received at the designated disposal facility, to allow time for data corrections, if necessary, and submission and uploading to the e-Manifest system.
Paper manifests, or hybrid manifests that start as paper manifests and are converted to electronic manifests, can still be used after June 30, 2018. Generators of hazardous waste should communicate with hazardous waste transporters and designated disposal facilities to discuss whether paper, hybrid, or electronic manifests will be used to track each hazardous waste shipment, since generators of hazardous waste may only use electronic manifests if the transporters and designated disposal facilities also use electronic manifests.
EPA will charge a fee to upload and store hazardous waste manifests in the e-Manifest system. This fee will vary based on the format of the manifest: fees for the use of paper and hybrid manifests will be greater than those for electronic manifests. Hazardous waste generators that wish to use the e-Manifest system must first enroll in the system via the EPA website (see below). Hazardous waste generators that do not enroll in the e-Manifest system must continue to save paper copies of manifests for use in annual hazardous waste reporting.
e-Manifest Registration
Hazardous waste generators must be enrolled in the e-Manifest system in order to sign electronic manifests, view manifests that have been uploaded to the e-Manifest system, or submit corrections to electronic manifests. Each individual accessing the e-Manifest system will need their own account. Accounts cannot be shared, even within a facility. In addition, each facility will need a designated site manager. EPA recommends that each facility register at least two site managers, because the site managers controls access to the facility’s accounts and administrative/signatory permissions.
If you are already registered for myRCRAid/Biennial Report as a site manager, you are already registered for e-Manifest. If you are registered as a viewer, preparer, or certifier, you will not need to re-register, but you will need to be granted access to applicable facilities by a site manager.
Resources
Information such as how to register for the program, frequently asked questions, and fact sheets for hazardous waste generators is available at the EPA e-Manifest website. https://www.epa.gov/e-manifest.
An EPA fact sheet is available on the Washington State Department of Ecology website.
https://ecology.wa.gov/DOE/files/a2/a2eaf257-1d99-4d20-8383-c6ea7fe199a9.pdf
The e-Manifest help desk for industry users can be reached between 8:00 a.m. and 6:00 p.m. ET toll-free at (833) 501-6826 or via email at helpdesk@epacdx.net
A YouTube webinar covering the e-Manifest user interface can be accessed at this website: https://www.youtube.com/watch?v=f48yIkdsIY4
Quick Reference Information
Q: I’m a hazardous waste generator. Was I required to register for the program by June 30?
A: No. Registration is optional and did not necessarily need to take place by June 30, 2018. Contact your transporter and/or designated disposal facility to determine if they are registered for the e-Manifest program.
Q: What about state-only wastes? Are they accounted for in the e-Manifest program?
A: Yes. Any shipment required to use a hazardous waste manifest, including RCRA hazardous waste, Toxic Substances Control Act–regulated waste, state-only hazardous waste, and special wastes that require the use of a hazardous waste manifest, is required to comply with the e-Manifest program.
Q: If a hazardous waste generator is still using paper manifests, how will they get back a completed manifest copy?
A: Generators may establish an account with the e-Manifest program to view copies of completed manifests electronically, even if their receiving facility is not registered for the e-Manifest program. Generators that wish to have paper copies of manifests will need to contact the designated disposal facility and make arrangements to receive paper copies of manifests.