On June 30, 2018, the Environmental Protection Agency (EPA) formally launched its new electronic manifest (e-manifest) system. This system will electronically track and store information of companies shipping hazardous waste throughout the nation. The new filing structure will ensure a more accurate, streamlined way of tracking hazardous waste through each stage of disposal.
Hazardous waste is managed under the Resource Conservation and Recovery Act (RCRA). One regulation dictates that each generator must use a round-trip manifest to monitor the movement of their waste. Previously, this was done through paper manifests. However, errors in information would occur, which caused confusion and improper management of hazardous waste. The EPA is hopeful the e-manifest system will provide better communication and shipment tracking to reach the goal of proper waste management from cradle to grave.
With each new system, there is always a transition period. Initially, paper manifests will still be available; however, the EPA's goal is to have all participants registered on the e-manifest system within five years. Before companies can use the new system, they must register. The EPA recommends having two site managers for each profile to provide flexibility for account management. In addition, each company must obtain an EPA identification number. Most generators are already required to have these. However, even very small quantity generators will need to obtain an EPA ID number to participate in the e-manifest system. Registration can be accomplished here. If generators choose not create e-manifest accounts, they should make arrangements with their waste disposal company to obtain paper copies of completed manifests.
As part of the new system, EPA has established fees to recover maintenance costs of the site. It is also a way to prod companies into the new system before the 2023 deadline. Manifest fees will be paid by the receiving facilities, often referred to as treatment, storage, and disposal facilities. However, it is anticipated that these fees will be passed on to the customer. A fee will be assessed for the specific type of manifest submitted to the system.
| Manifest Type | Fee |
|---|---|
| Mailed | $20.00 |
| Scanned image upload | $13.00 |
| Data + image upload | $7.00 |
| Electronic manifest | $4.00 |
*Fees will increase every two years.
The EPA has also established a dedicated web page with links to fact sheets and frequently asked questions that may apply to your specific operation.
Conversion to a digital system always has pros and cons. There are still questions and concerns that must be addressed with the new system. It will be some time before there is a complete transition to the electronic version; nevertheless, the e-manifest system is in place. It is encouraged to familiarize yourself with the new system. It will save money and headaches before the phase-in period ends in 2023.