e-Manifest Activites in Place

Since the inception (6/30/18) of USEPA’s electronic Hazardous Waste manifest system, WTS has been diligent in communicating with our stakeholders regarding the status of the system. As we all know, there is an ongoing struggle around industry adoption of the e-manifest system, and we have focused on the implementation issues in our communication. We have decided that it might be best at this point to step back and highlight what parts of the system are actually in place and that we feel you should be aware of. The following is a brief Summary of e-Manifest Activities in Place:

1. REGISTRATION
   • All “handlers” – anyone who prepares, signs or executes a Hazardous Waste Manifest – should now be registered in the e-Manifest system.
   • Registration is through the current EPA RCRA info system, where e-Manifest is a separate module. This is the same platform that you may currently be using to file Biennial reports or obtain an EPA Identification number.
   • Each site – think of a site as being tied to an EPA Identification number – has a designated Site Manager who handles the original registration. It is recommended that there be at least two designated Site Managers per site.
   • The Site Managers will then designate all parties at their site who will then need to register individually as users – i.e., anyone who is authorized and trained to sign a Hazardous Waste Manifest – generators, drivers, receivers.
   • If you are currently registered in the EPA RCRA Info system as a Site Manager for purposes of submitting your biennial report, you do not need to register again as a Site Manager for e-Manifest but you will need to request and be granted access to e-Manifest for specific sites. You may do so via your user profile.
   • If you have never registered in the EPA RCRA Info system, you can follow the instructions in USEPA’s Creating an EPA e-Manifest Site Manager Account guide by clicking here.
2. DISTRIBUTION
   • For the foreseeable future, WTS clients can expect to receive their PAPER manifests in the same fashion they currently do. Remember – the e-Manifest program is strictly for Hazardous Waste Manifests and has no bearing on Bills of Lading, LDR’s, ERG guides, Marks and Labels, etc. that WTS may currently be supplying to you.
   • Generators should continue to use the same process they currently do after signing the manifest and after the transporter signs, namely keep their copy and send the remaining copies with the load.
   • Individual states may still require that generators submit a copy of the generator copy manifest. Check with your state or with your WTS Technical Representative.
   • The TSDFs will accept and execute the paper manifests. TSDFs are then responsible for submitting the executed copies to the EPA within 30 days of delivery of the waste. TSDFs are no longer required to distribute executed copies to either their state or the generator’s state. TSDFs submit executed copies to the EPA in a variety of fashions including mail (until 6/30/21) or data uploads.
   • EPA is assessing a fee based on the type of submission and the fee will in turn be charged to the generators. See the following section for information regarding the current Fee Structure.
   • Based on the individual TSDF’s protocol, generators will receive their copy of the executed manifest via the e-Manifest portal or regular mail, e-mail or TSDF specific web sites as they do today. As of this writing, it appears that the majority of the TSDFs are continuing to distribute the executed manifest in the same manner as they always have. However, this does point out the need to make sure generators are registered in the e-Manifest portal as at some point this may be the method for generators to receive and store their executed copy. The requirement for a generator to maintain a copy of an executed manifest for 3 years remains in effect. “Storage” in the individual generators e-Manifest portal site fulfills that obligation.
   • Receiving facilities will no longer be able to mail paper copies of manifests to USEPA for reporting after June 30, 2021. As mentioned above, it is the responsibility of the receiving facility to submit a copy of the executed manifest to USEPA. Since the inception of the program, this could be done in one of three ways – a paper copy, an image file (scan) or a data plus image file. The fees charged for the submission vary based on the method of the submission. This will have no effect on generators utilizing paper manifests and it will simply force the receiving facilities to use one of the other two methods if they weren’t already. As the paper submission was the most expensive of the options, there is a potential for a small cost savings back to the generator.
3. FEES
   •        The current fee structure is as follows:
     • Note that this structure is in effect until September 2021 at which time the fees are expected to be adjusted.
     • There will also be an elimination of the “Mailed in Paper Manifest” fee as TSDFs will no longer be allowed to submit paper copies to the USEPA effective 6-30-21
     • You may very well see an additional  management fee or markup from the TSDF community to cover administrative costs associated with the program.

     • Manifest Submission Type	Fee per Manifest
       Mailed in Paper Manifest	$25.00
       Scanned Image Upload	$20.00
       Data + Image Upload	$14.00
       Electronic Manifest (Fully Electronic & Hybrid)	$8.00

4. PUBLIC ACCESS
   • One facet of the program that is also in effect (as of 11/01/18) is public access to view executed manifest information via the RCRAInfo Web.
   • Within 90 days of receipt at a TSDF, information regarding the shipment (generator, transporter, TSDF, volumes, waste codes, management method codes, shipment types, etc..) is posted one the RCRAinfo site.
   • Note that the search process is cumbersome and very slow.
   • There are some restrictions in place for high hazard and chemicals of concern from a security standpoint.