October 2018

Here’s the latest update on e-Manifest implementation:

• The transition to a fully electronic system has shown little or no progress since our last update. On 09/26/18, USEPA reported that they have received 154,848 manifests since June 30th. Of them, only 805 have been transacted fully electronic. That is still < 1%.
• The vast majority of the commercial TSDF’s currently do have the ability to accept electronic manifests, however general acceptance has been very slow on the uptake.
• The transportation industry in particular is struggling with issues such as individual driver registration, drivers having electronic access to the e-Manifest portal, etc.
• As you recall from previous updates, EPA had allowed TSDFS’s to have until 09/30 to get all manifests shipped post 6/30 uploaded into the E-manifest portal. Now that we have entered into October, all generators should be able to access their executed manifest copes from the portal.
• Even though you may have already received your executed manifest copy for post 06/30 shipments through conventional means, we are strongly encouraging all generators to access the e-Manifest portal to check for copies. If nothing else, this will at least get you familiar with the process you will be working with in the future.
• The other part of the e-Manifest program that is in place is the collection of fees. You should see fees assessed on all shipments that utilized a Hazardous Waste manifest post 06/30. This includes state regulated wastes that ship on Hazardous Waste manifests.
• WTS still feels that the full implementation of the e-Manifest program will occur gradually and thus will take some time. We are continuing to work with EPA, the TSDF community and the Waste Transportation network to monitor progress.