The Future of Hazardous Waste Reporting by David Green, MDNR, at REGFORM's Missouri Hazardous Waste Seminar, Nov. 15 2012
The Future of Hazardous
Current Reporting Requirements
Report (MO 780-
(EPA form 8700-13
Annually NO NO
Quarterly NO YES
assumed to be
assumed to be
SQG or LQG
* Federal Requirement
Current Reporting Statistics
Statistics for the July 1,
2011 to June 30, 2012
Total reports received 3200 190
%Paper 70% 49%
%Excel 30% 51%
Total records in the reports 16000 26100
%Paper 60% 6%
%Excel 40% 94%
The Hazardous Waste Program is beginning
to modernize the means by which we accept
What is driving this change?
– Allows for LQGs and
TSDFs to report annually if
they report electronically by
the means specified by the
– This must be implemented
by the July 1, 2015, to
June 30, 2016, reporting
• “Hazardous Waste Electronic
Manifest Establishment Act”
– Signed into law by the
president last month.
– Must be implemented
within three years of the
law being enacted
(by October of 2015).
What is being done now?
• The Hazardous Waste Program has
begun working with information technology
staff to develop a new electronic reporting
system. This system will need to be able
to handle the large amounts of data that
will be received at one time when LQGs
and TSDFs begin filing their reports
What will reporting look like?
Based on Hazardous Waste Forum discussions, we believe that
reporters would like a system with the following features:
– Web based
– Allows for both direct data entry and loading data from reporter’s
own data systems
– The ability to take the data submitted to us and use it to create
the reporter’s “Biennial Report”
• The reporter will still have to go into the biennial report and add codes that
we do not collect on our reports
• Since the state reporting cycle and the biennial reporting cycles do not
coincide, we would have to add a field to determine when the waste was
shipped/received. Without that additional field, this feature will not be
How will the Electronic Manifest impact reporting?
• We plan to make the schema that we use
as close as possible (hopefully identical) to
the schema that EPA will use to accept
electronic manifest data from the TSDFs.
This will allow those that want to upload
data to use a single application in their
Will the Electronic Manifest change state reporting requirements?
• Two elements must exist in the Electronic Manifest system before
state reporting requirements could be changed.
– All manifests, both paper and electronic, must be entered into
the national manifest database
• The law allows for rules to be written to require this.
– The amount of waste shipped must be easily converted to tons.
• This will require that the weight of the waste will be able to be determined
from the information on the manifest, or entered into the national manifest
• The current paper manifest does not allow for this when the waste is shipped
• The HWP would like to see the EPA require the TSDFs to enter a “weight
received” into the national manifest database, even if that field is not added
to the actual manifest.
What will change if those requirements are met?
It would be possible to eliminate the reporting requirements
with the following exceptions.
– Any waste that you currently report that is not manifested will still
need to be reported as you do currently.
– TSDFs that receive waste and then ship the waste to another
TSDF on a new manifest ,will still need to file their report
indicating that this is the case. Currently, this is done by marking
“A” in the tax code field of the “Generators Hazardous Waste
– Sites that have a state approved remedial plan and enter “B” in
the tax code field will also need to file a report.
Have an idea about electronic reporting?
Please tell me about it!