Will e-Manifests Make Life Easier or Harder for EHS Pros?

Will e-Manifests Make Life Easier or Harder for EHS Pros?

Hazardous waste shippers now stand on the brink of a major change in the way shipments are documented and tracked. On June 30, 2018, US EPA will launch its new Electronic Hazardous Waste Manifest (e-Manifest) system to trace the journey of hazardous wastes from generators to waste brokers to transporters to treatment, storage, and disposal facilities (TSDFs).

Advances in technology often simplify our lives and make our work day easier—will this be the case with e-Manifests? Or will the new electronic tracking system become a boondoggle for shippers, transporters, and receiving facilities?

What is a Hazardous Waste Manifest?

First, let’s talk about what the new electronic system will replace. When a business ships a regulated hazardous material in the US, they must accurately describe their material on a shipping paper. For hazardous wastes, shippers have for years used the Uniform Hazardous Waste Manifest (EPA Form 8700-22). The manifest provides essential information—Federal or State waste codes, for example—that ensures the waste is safely transported, tracked, and disposed of. 

E-Manifest History: 2012—present

In terms of regulatory action, the switch to e-Manifests moved relatively fast. The President signed the Hazardous Waste Electronic Manifest Establishment Act into law in October 2012, which gave EPA a three-year window in which to establish its e-Manifest system.

EPA established a regulatory framework to phase out paper manifests in 2014 and by April 2016 had selected a Board of Experts to advise the agency on system performance, fees, and other considerations. This year, EPA announced e-Manifest user fees and launched an e-Manifest test environment that hazardous waste stakeholders can use to test drive the new system.

What Benefits Do E-manifests Offer?

Will e-Manifests really make the jobs of shipping, transporting, or storing hazardous waste easier? The e-Manifest will offer real benefits for generators, transporters, and TSDFs, including:

  • Provides real-time tracking of hazardous waste shipments
  • Offers more timely, accurate data
  • Allows facilities to correct Manifest errors before they cause confusion or fines
  • Creates one central location for reporting manifest data to EPA and/or states

Despite the benefits of electronic manifests, some professionals may feel more comfortable sticking with paper. How long will EPA allow facilities to continue using paper manifests? Read on to find out. 

Find out what you need to know to start using the new electronic Manifest system. Join Lion instructor and CDGP Joel Gregier for the EPA’s New E-Manifest System Webinar on June 19 or June 28. Enroll now or see the full 2018 schedule

Can I Still Use Paper Copies of the Manifest After June 30?

Initially, anyone who creates a hazardous waste manifest—generators, transporters, brokers, TSDFs, etc.—can continue to use paper manifests for a limited time. Facilities should carefully consider the costs of sticking with paper, however. While receiving facilities will pay the user fees to support the new system, the highest fees will be placed upon those who use paper manifests. Generators or transporters may see these high fees for paper users reflected in the cost of doing business moving forward. The lowest fees, meanwhile, are reserved for users of the new electronic system.

In addition, EPA has designated a mandatory phase-out period for paper manifests. TSDFs must begin using electronic manifests within three years and generators must get on board within five years.

Where Do I Create E-Manifests?

To create an e-manifest, you will use EPA’s RCRAInfo Portal, found at https://RCRAinfo.epa.gov. The RCRAInfo portal itself is not new; generators in states which have opted-in to RCRAInfo already use the system to meet other RCRA recordkeeping and reporting responsibilities, e.g., biennial reports and site notifications. 

“Any brand-new system can be intimidating at first, especially when technology is involved. But EHS professionals will find that once they get set up in the new system, completing Manifests is no more difficult than it was before,” says Joel Gregier, Certified Dangerous Goods Professional and lead instructor for Lion Technology’s new e-Manifest webinar.   

What is a “Hybrid Manifest”?

As of June 30, generators will have three options for manifesting hazardous waste shipments: Paper manifests, electronic manifests, or hybrid manifests. A hybrid manifest starts with a paper manifest signed by hand by the generator and the initial transporter. Later, the transporter and subsequent waste handlers will complete the process by entering the necessary information into the electronic system.

Can I Use E-Manifests for State-Regulated Wastes?

As we approach the June 30 “deadline” to start using e-Manifests, many professionals are wondering whether an exception or exclusion may be coming for their state. The short answer is no. All states will be required to use RCRAInfo for the creation of hazardous waste manifests and will be opted into the new e-Manifest system automatically.

In California, Texas, New York, and other states with robust State hazardous waste programs, generators use state-specific waste codes to describe their shipments. These state codes will be available in the RCRAInfo E-Manifest creator program.  After choosing a site location, generators and TSDFs have the option to add applicable Federal and/or State waste codes to the “Waste Line” on any e-Manifest. EPA has stated that all applicable State codes will be available for inclusion on the e-Manifest by June 30.

Unlike other US EPA hazardous waste rule changes, which allow for a one- to two-year transition period for states to update their regulations, e-Manifests go live everywhere on the same launch date, June 30. E-Manifests Are Coming No Matter What—Be Ready.

Join expert instructor and CDGP Joel Gregier for a one-hour webinar on June 19 or June 28. The live webinar covers what EPA expects from generators, transporters, and TSDFs, how to select the best option (paper or electronic) for your facility, and how the electronic manifest affects other paperwork requirements like LDR notifications, State hazardous wastes, and more.  

Trusted RCRA Hazardous Waste Training

E-manifests aren’t the only major change hazardous waste generators face in 2018. EPA’s Hazardous Waste Generator Improvements Rule is in effect now, and includes stricter contingency planning and reporting rules, updated container labeling standards, re-organized generator regulations, new reliefs, and more. Be confident you know what to expect when your state adopts these landmark RCRA updates.

To get up to speed and meet EPA’s training mandate at 40 CFR 262.17, catch the RCRA Hazardous Waste Management Workshop in Williamsburg, Charlotte, Orlando, Atlanta, Birmingham, Nashville, Memphis, and Little Rock in July.

See the full line-up of RCRA hazardous waste training options at Lion.com/RCRA.

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