If signing paper manifests is not reasonably practical, EPA encourages use of the e-Manifest system.
If e-Manifest system is not an option: (source: EPA Memorandum Dated August 20, 2020)
- The transporter should write the name of the generator in Box 15 and, under “Signature,”
should write “COVID-19 signature substitute,” or abbreviated as “COVID-19 sig. sub.,” if there is insufficient space in the box;
- The generator should provide a signature substitute in a cell phone text message, email, or hard copy letter mailed to the transporter and designated facility. The generator should use one document/transmittal to cover all manifest activities per transporter/designated facility throughout the duration of this temporary policy; and
- The transporter or designated facility should write the following in Box 14 of the manifest: “documentation for generator signature substitute available upon request.” Generators and transporters taking the steps outlined above should maintain this documentation for three years from the last shipment needing a signature substitute.
An example, per the EPA, of the language for a signature substitute over text message, email, or hard copy letter is as follows:
“I authorize my signature for Box 15 of the Uniform Hazardous Waste Manifest, EPA
form 8700-22/22A, for Generator/Offeror’s Certification for all hazardous waste shipments with [transporter company name] as transporter and [designated facility company name] as designated facility during the time of EPA’s policies regarding signature of hazardous waste manifests during the COVID-19 public health emergency.”
This temporary manifest signature policy has been extended to remain in effect until November 30, 2020.