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August 2018

Here’s some of the latest news regarding e-Manifest since the June 30th implementation:

  • Though e-Manifest was ”successfully” launched on June 30th, the transition to a fully electronic system continues to lag. According to the EPA – as of yesterday, they have received 55,696 manifests since the June 30th implementation and only 534 were fully electronic. That’s less than 1%.
  • Paper manifests continue to be the manner of choice by the regulated community. As you know, there is no firm deadline requiring the use of the full electronic manifest system, though EPA continues to expect full adoption occurring over the next few years.
  • One significant impact for generators currently is making sure that they are receiving or have access to their fully executed copy of a manifest utilized for a post 6/30 shipment. Many or most of the TSDF’s are continuing to distribute in the same manner that they were prior to the 6/30 implementation as well as submitting into the e-Manifest portal. If the TSDF has elected to just submit copies to the portal, (the rule states that the submissions have to be done within 30 days of receipt) note that EPA has granted a temporary extension to the TSDFs that allows them to submit paper manifests to the EPA that they receive between June 30, 2018, and September 1, 2018 until September 30, 2018.
  • It is the responsibility of the TSDF to submit the executed copy of the manifest to the portal, not the generator.
  • However, the generator still has a responsibility to maintain a copy of the executed manifest for three years post shipment. The rule does allow generators that have registered with e-Manifest to use their e-Manifest account to store and retrieve their manifest copies. Thus, all generators need to ensure that they have a copy of the executed manifest either in their files or in their e-Manifest account.
  • Hopefully, by this time the majority of you have met the registration requirements for e-Manifest. Let your WTS technical representative know if you are having any issues.
  • You no doubt have noticed that the fee structure is in place and charges are appearing on invoices.
  • WTS still feels that the full implementation of the e-Manifest program will not occur for some time. We are anticipating more progress in functionality during the remainder of this year and progress towards full implementation in 2019.