e-Manifest: The most recent compliance date of January 22, 2025 has come and gone. By now all Small Quantity and Large Quantity Generators of Hazardous Waste should be successfully registered in RCRA Info. Each account must also have a designated Site Manager and/or e-Manifest certifier. TSDF’s are no longer obligated to return hard copies of executed manifest copies to generators. The designated Site Manager and/or e-Manifest certifier will be able to access the executed manifest copies in their RCRA e-Manifest portal. WTS has canvassed all of our TSDF partners and the vast majority of them have already ceased transmitting executed manifest copies to generators or are planning to cease sometime in 2025.
Link to our two prior updates about e-Manifest: 01/2025 and 11/2024
Updated Management Method Codes: As we reported earlier (link to article), the H141 Management Method Code (for storing, bulking and transferring Hazardous Waste by TSDF’s without treating or disposing of them) recorded on manifests and hazardous waste reports is being updated by using more detailed “S” codes which will show the ultimate disposition method after transfer. Though this change became effective in January 2025, it is voluntary at this time and H141 may be used until January 1, 2027 including on reporting for 2025 and 2026. At this time it appears that most of the TSDF’s are continuing to use the existing H141 code. Transition to the new codes will become mandatory on January 1 2027.
