As evidenced below, Industry participation in the USEPA’s Electronic Hazardous Waste Program (e-Manifest) continues to be dismal. The reasons continue to be the same – no regulatory driver to force participation; confusion over intent and practicality, lack of interest/participation from generators and transporters and a general reluctance from the TSDF community to engage in a new program when they have already invested in propriety systems of their own. The single most significant impact of the system (beyond Fees!) has been the central collection of executed manifests by the USEPA from the receiving TSDF’s.
There are some developments around that we do want to make our stakeholders aware of:
- WTS was recently notified by one of our major TSDF partners that they will no longer be mailing executed manifest copies back to the generator. Generators will be expected to receive their copies via their RCRA-Info e-Manifest portal. Though the TSDF company will also be emailing executed copies back to the generator for the time being, this is thought to be for the short term and the expectation is that more TSDF’s will follow suit. Generators are still required by regulation to retain executed manifest copies for three years from date of shipment. This is again another important reason for all generators to be registered in the e-Manifest program. Please refer to our previous updates on this topic or contact your WTS Technical Representative.
- USEPA will be conducting virtual public meetings “to discuss how to increase adoption of electronic manifests” on October 27th and November 3rd. The agenda for the meetings will be identical. Registration is available through the following links:
- On September 29, 2021 USEPA reported the following “All Time Submission Summary” (from June 30, 2018 to September 27, 2021) for the e-Manifest program:
- Submitted manifests: 5.8 M
- Submission breakdown:
- Data + Image: 4,750,868
- Image Only: 824,372
- Mail: 227,120
- Electronic: 20,135 (0.3% !!!!)
- As a reminder and as previously communicated, TSDF’s can no longer mail manifest copies to the USEPA. All executed manifests will be transmitted in some automated fashion– Image Upload, Data+Image Upload and Electronic (Note: This will have no bearing on the generating community). The User Fees as of October 1, 2021 are as follows and Beginning October 1, 2021 – Any manifest that originates (signed by the generator) will be charged the fiscal years 2022 and 2023 user fee rate when submitted to the e-Manifest system by the receiving facility:
|Data + Image Upload||$13|
We will continue to monitor and report on this program. Should you have any questions or comments on this matter, please do not hesitate to contact your WTS Technical Representative. Thank you.