Hazardous Waste Manifest - the new eManifest Rule
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The EPA is transitioning the paper-based hazardous waste manifest system to a national electronic system (e-Manifest) by October 2015. The e-Manifest system will track hazardous waste shipments electronically from generators to disposal facilities. A rule establishing user fees to fund the system will be finalized in 2014. Generators, transporters, and disposal facilities should prepare for the transition by communicating with EPA and each other, and monitoring the EPA's website for updates.
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Hazardous Waste Manifest - the new eManifest Rule
- 1. Hazardous Waste Manifest System Modification What You Need to Know Ahead of August 6, 2014
- 2. Agenda Overview of the e-Manifest rule Benefits & Impact Key Dates Determination of Rollout & Tracking EPA’s Progress Fees and Manifest-Related Services Implementation at State Level Compliance Strategies &Resources
- 3. Overview of the e-Manifest rule
- 4. Overview e-Manifest: national electronic manifest system and user service fees to fund the development Upgrade current paper-based system Authorizes e-Manifests under RCRA Emergency responder access
- 5. Overview e-Manifests = legal equivalent of paper system Manifest forms are used to track shipments of haz waste from a generator to disposal New tools to reduce the reporting burden
- 6. Overview More steps needed to fully implement e-Manifest Establish the system and initial fee structure EPA will work with states, industry, stakeholders
- 7. Requirements of e-Manifest “to the same extent as paper manifests under applicable Federal and State law…” Track and maintain legal accountability of… State authority to access paper copies Access to all publicly available info Can I still use paper??
- 8. Solid Waste Disposal Act 42 U.S.C. 6901 amended by inserting at the end of the TOC for Subtitle C:
- 10. Impact to State Agencies EPA wants to streamline with state requirements that currently require paper manifests Get involved Talk to State IT staff Check e-Manifest website often
- 11. Ease of Access EPA initiative to provide the agency, states and public with easier access to environmental data. Electronic reporting = enforcement Reduce burden on preparing written manifests
- 12. Impact to RCRAInfo e-Manifest will be separate from RCRAInfo
- 13. Impact on other shipment tracking systems “In Transit,” “Delivered” after manifest is signed Differences: Applies to entire shipment Tracks additional information 40 CFR coordination EPA still evaluating technical implementation of real-time tracking of shipments.
- 14. Inclusion of all manifests Paper and e-Manifest data Transition from paper to e-Manifests Fee structure
- 15. Other benefits Drop-down menus and pre-populated forms Track shipments and receive delivery and acceptance confirmations Recordkeeping Mobile devices carried on transport vehicles Cradle to Grave tracking Eliminate 6 page paper manifest
- 16. Impact on other Regs Electronic reporting for other permits - Stormwater, NPDES Permit records and compliance history accessible by the public Stakeholders concerned about accuracy of data and data being misinterpreted or misconstrued Stormwater permit initiative = $60M budget request for 2014.
- 17. Key Dates
- 18. One Year Rule Oct 2012: Haz Waste e-Manifest Establishment Act October 5, 2013: Authorizes e-Manifests. System and fee structure must still be established by EPA to implement the e-Manifest. The NEXT rule will establish the initial fee structure and announce the actual implementation and compliance date for their use. Publicly available data…
- 19. System Online e-Manifest system to be online by October 2015 Shipments cannot be electronically tracked until then Funding has not been received yet
- 20. Determination of Rollout & Tracking EPA’s Progress
- 21. When will it be online? 3 years from the signing of the Act Signed October 2012 Online by October 2015
- 22. Advisory Board No later than 3 years after enactment of bill 9 members Chairperson 8 appointees by Administrator 2 = IT 3 = users 3 = State rep
- 23. Timeline Rule was finalized in early 2014 Next rule to establish fees October 2015 deadline Technical details: system design, operation, security, fee structure
- 24. Final Rule Electronic signature legal and enforceable Manifest info – available after 90 days after considered “complete and final” Opt-out options Paper and electric DOT shipping paper requirements Record retention requirements Electronic signature Authorization
- 25. Fees and Manifest-Related Services
- 26. How will the fees be set? EPA to set initial fees via rulemaking in consultation with IT vendor(s). 2014 Operation, maintenance, and development of system Establish board by October 2015
- 27. Fees Stakeholder communication and participation Will e-Manifest system conflict or add work to current DOT requirements. It is still necessary to carry a printed manifest on transport vehicle during transport of haz waste subject to haz mat regs
- 28. Implementation at State Level
- 29. Non-RCRA wastes requiring manifests under state law Fed RCRA haz wastes State-regulated wastes that require manifest by state law States will not be permitted to require different or additional e-Manifests
- 30. State Compliance Complete the facility portion of the applicable manifest Sign and date the facility certification Submit to the system a final copy of the manifest data for processing purposes
- 32. Get Ready for e-Manifest Get Involved Talk to your generators, transporters, TSDFs, IT staff Check the e-Manifest website often Subscribe to the e-Manifest ListServ
- 33. Generator Benefits: Fill out manifests online Track shipments and receive confirmation Recordkeeping Communicate and participate with EPA Communicate with transporters and TSDFs
- 34. Transporter Benefits e-Manifest on mobile devices Cradle to Grave racking Eliminate current 6 page paper manifest Minimal need for DOT-required paper manifests
- 35. TSDF TSDF = key customer of e-Manifest system Communicate and participate with EPA Communicate with generators and transporters
- 36. Haz Waste Shipments by Rail Electronic waybill system to track location/status e-Manifest is primarily for highway shipments EPA will coordinate with rail industry
- 37. Concept of Operations EPA will host outreach and communications webinars and meetings in 2014 with stakeholders to discuss technical design
- 38. Online Resources Text of the bill (21 large text pages) http://www.gpo.gov/fdsys/pkg/BILLS- 112s710is/pdf/BILLS-112s710is.pdf EPA Landing Page for e-Manifest http://www.epa.gov/waste/hazard/transportatio n/manifest/e-man.htm Con-Ops doc http://www.epa.gov/waste/hazard/transportatio n/manifest/pdf/eman_conops.pdf
- 39. EPA Points of Contact Per Con-Ops Doc
- 40. e-Manifest ListServ Subscribe by sending blank message to eManifest-subscribe@lists.epa.gov Contribute by sending message to eManifest@lists.epa.gov Unsubscribe eManifest-unsubscribe@lists.epa.gov
- 41. Thank you! Continue the conversation – Abby Ferri, CSP abbyferri@gmail.com 612-567-9981 @abbyferri Abby Ferri, CSP +AbbyFerriCSP
Editor's Notes
- An overview of the national e-Manifest system rule, including a discussion of key elements and rule process development Why the EPA believes this rule will benefit the regulated community A detailed analysis of the rule's practical impact Key dates you need to know about How the EPA will determine when the e-Manifest rule is fully ready for rollout A discussion about the schedule for fees and manifest-related services components How to track the EPA's progress on the rule rollout Suggested approaches for developing your compliance strategies so you can ensure compliance with the new rule How implementation will occur at the state level How to identify and evaluate resources to help you develop a successful compliance strategy for the e-Manifest system rule
- On January 13, EPA Administrator Gina McCarthy signed a final rule authorizing the use of electronic hazardous waste manifests, or e-Manifests. A pre-publication version of the rule is now available on EPA's e-Manifest webpage. The agency will link to the official version of the rule once it is published in the Federal Register.The final rule will provide hazardous waste handlers with the option to complete, sign, transmit, and store manifest information electronically. The e-Manifest system is anticipated to significantly improve the delivery of waste tracking services to the public and the delivery of “high quality manifest data to manifest users and to government officials.” EPA also anticipates that e-Manifests will substantially reduce costs relative to the paper manifest system now in place. In fact, the agency concludes the savings from paper to electronic manifesting could be as much as 300,000 to 700,000 in paperwork burden hours and more than $75 million per year.Once the e-Manifest system is up and running, electronic manifest documents will be the preferred alternative to paper manifest forms. However, users may elect to opt out of electronic submittals to the e-Manifest system and continue to use paper manifests to track hazardous waste shipments. These paper manifests will in turn be submitted by the designated disposal facility for inclusion in the e-Manifest system.The final rule also addresses how the agency will impose “reasonable” user service fees as a means to fund the development and operation of the e-Manifest system. EPA will publish a subsequent notice to announce the user fee schedule for manifest-related activities.While the new final rule is major step in moving toward implementing the e-Manifest system, hazardous waste handlers cannot begin tracking their waste shipments electronically until the system is fully established. The Act calls for the system to be online by October 5, 2015.
- Senate Bill 710 - This final rule also implements certain provisions of the Hazardous Waste Electronic Manifest Establishment Act, Public Law 112-195, which directs EPA to establish a national electronic manifest system (or e-Manifest system), and to impose reasonable user service fees as a means to fund the development and operation of the e-Manifest system. The EPA has issued a final rule that it says is a crucial step in developing a national electronic manifest (e-Manifest) system, which will upgrade the current paper-based system of tracking hazardous waste to an electronic one.The final rule authorizes the use of e-Manifests to track hazardous wastes under the Resource Conservation and Recovery Act. This will allow the current process, which requires paper forms, to be streamlined and greatly reduce the millions of paper manifests produced each year.Once fully implemented, the national e-Manifest system will give emergency responders greater access about the types and sources of hazardous waste that are in transit between generator sites and waste management facilities, says Mathy Stanislaus, EPA assistant administrator for the Office of Solid Waste and Emergency Response. The electronic system will apply in lieu of inconsistent state programs.
- The Hazardous Waste Electronic Manifest Establishment Act requires the EPA to issue a regulation authorizing the use of electronic manifests as the legal equivalent of the current paper manifest forms used to track shipments of hazardous waste from a generator’s site to the ultimate site of disposal. The EPA’s goal is to promote the greatest possible use of electronic manifests.The e-Manifest program is the vanguard of the agency-wide initiative to develop new tools to reduce the reporting burden on regulated entities, and provide the agency, states and the public with easier access to environmental data. The EPA estimates the national e-Manifest system will ultimately reduce the burden associated with preparing shipping manifests by between 300,000 and 700,000 hours, and result in cost savings of more than $75 million per year for states and industry.
- The final rule will establish the legal and policy framework for using electronic manifests; however, several more steps will be needed before the e-Manifest program can be implemented. These include establishing the system and initial fee structure.This year, the EPA will work with states, industry and other stakeholders to develop plans for the many key aspects of the system and address concerns of intersystem compatibility. The agency will also begin developing the initial fee structure of the system, including implementation and compliance dates, through a rule-making.
- REQUIREMENTS.—The regulations promulgated pursuant to subparagraph (A) shall ensure that each electronic manifest pro- vides, to the same extent as paper manifests under applicable Federal and State law, for— ‘‘(i) the ability to track and maintain legal accountability of— ‘‘(I) the person that certifies that the information provided in the mani- fest is accurately described; and ‘‘(II) the person that acknowl- edges receipt of the manifest; ‘‘(ii) if the manifest is electronically submitted, State authority to access paper printout copies of the manifest from the system; and ‘‘(iii) access to all publicly available information contained in the manifest. The new rule specifies that the e-Manifest documents obtained from the national system EPA is developing would be the legal equivalent of the paper forms that are currently being used to track hazardous waste shipments. Waste generators and transporters can opt to continue to use paper documents, but the paper manifests would need to be submitted to EPA for inclusion in the electronic system. The rule also specifies how issues of public access to manifest information will be addressed when manifest data are submitted and processed electronically.
- CONFORMING AMENDMENT.—The table of con- tents of the Solid Waste Disposal Act (42 U.S.C. 6901) is amended by inserting at the end of the items relating to subtitle C the following: ‘‘Sec. 3024. Hazardous waste electronic manifest system.’’.
- The EPA estimates that the rule will cover approximately 160,000 businesses and other entities involved in sending, receiving and transporting the nearly 6 million tons of hazardous waste that moves around the country each year. Between 4.6 million and 5.6 million EPA hazardous waste manifests are used to track that waste from generation to disposal, according to the agency. EPA expects the eManifests to be the main means for tracking hazardous waste shipments. The EPA will consider potential fee incentives as a way to promote the option of using the e-Manifest.
- Several states require that paper hazardous waste manifests be delivered to the state at various stages in the shipping process. For these states, e-Manifest will provide some significant improvements in the timelines, accuracy, and efficiency of data collection. However, e-Manifest will also create some significant changes to how manifests are delivered to the states. EPA is seeking to learn as much as we can about state requirements, including specific state reporting requirements and Quality Assurance/Quality Control requirements. If you are a state that currently does not collect manifests, EPA also values your input as to how e-Manifest may impact you in the future.Here are a number of things you can do as states to make sure that you’re ready for e-Manifest:Get Involved: In order to ensure that e-Manifest integrates into your business process, you can start now by making sure that EPA understands your state reporting process, including any data systems that you currently use for tracking manifests. Participate in one of EPA’s system requirements meetings or webinars.Talk to your state IT staff: EPA envisions using the to provide manifest information to the states. Currently all states have the ability to receive information via the Exchange Network, but additional work will need to be done in order to receive specific manifest data, and to incorporate those data into the state systems. If you are currently not familiar with the Exchange Network, EPA encourages you to visit the Exchange Network Website to not only learn more about the Exchange Network, but also to find out who in your state can provide more information.Check the e-Manifest website regularly New information will be posted to the e-Manifest website as it becomes available. The best way to stay informed will be to check the website regularly.As more details on e-Manifest become available, this list will expand. Make sure you check back to see the most current list of recommendations. While not yet finalized, e-Manifests will likely be executed by using a PIN/password and ID system under the following steps:· the generator enters waste descriptions, certifies in the system that the waste shipment is properly packaged, and presents a government-issued photo ID to the transporter during pickup. The transporter in turn logs on to their system account and enters the pickup date and the last five digits of the ID into the system, certifying witness of the generator’s signature;· the transporter acknowledges receipt of the waste in the system, and a printed copy of the e-Manifest is carried by the transporter until delivery to comply with DOT regulations; and· when the transporter arrives to drop off the waste at the receiving facility, the facility has thirty days to log on to the system and enter the date of receipt and any issues with the waste shipment.Although the rule has been enacted by EPA, the e-Manifest system is not required to be implemented until October 5, 2015. A schedule of user fees and a specific implementation date will be revealed in a future rule by EPA. The system will automatically take effect within all states on the date of implementation. Ultimately, States are required to adopt equivalent program revisions consistent with the requiremets.
- The e-Manifest program is the vanguard of the EPA-wide initiative to provide the agency, states and the public with easier access to environmental dataElectronic reporting increases the likelihood of enforcement, given the increased availability of data and ease of data analysis. On the benefits side, EPA estimates the national e-Manifest system will reduce the burden associated with preparing shipping manifests by between 300,000 and 700,000 hours, and save states and industry more than $75 million per year. To use the e-Manifest system, the rule requires that all entities in the chain of custody agree upfront to use the system instead of using paper forms. Generators should ensure that trnasporters and receiving facilities are willing to participate. the e-Manifest system is XML-based. Entities who want to use the system should ensure their computing system supports XML architecture; and he rule states that manifest data are not confidential business information. Aggregate data requests from the e-Manifest system may possibly reveal customer lists for receiving facilities, or process information for generators.
- The Resource Conservation and Recovery Act (RCRA) requires hazardous waste shipments be accompanied by a manifest from point of origin to their final destinations as part of its cradle-to-grave management of hazardous waste under RCRA Subtitle C. Currently, multiple copies of paper manifests are used. e-Manifest would be a separate system from RCRAInfo. With e-Manifest development and implementation over the next three years, EPA does not see any immediate impact to the RCRAInfo system or its users. EPA’s planning and requirements gathering efforts for e-Manifest will explore possible linkages between the e-Manifest system and RCRAInfo, especially in identifying valid hazardous waste handler identifiers (the EPA ID from the Uniform Manifest and the Site ID form) and providing valid look-up values (i.e., valid waste codes, units of measure, etc.).
- E-Manifest will provide information to users indicating where the waste is in the shipping process (i.e., ‘In Transit’, ‘Delivered’, etc.) after a manifest is signed. Conceptually, this type of shipment tracking is very similar to other shipment tracking systems that report on the status when a package is scanned. There are some distinct differences about hazardous waste manifests:A hazardous waste manifest applies to an entire shipment, as opposed to individual packagesA hazardous waste manifest tracks additional information (different from other commercial shipment systems) that are unique to the tracking of hazardous waste, andBecause manifests are required by 40 CFR, the electronic signatures used as part of the manifest process must meet the EPA’s standards and requirements for ensuring legal defensibility of electronic signatures. Currently, this standard is referred to as EPA’s Cross Media Electronic Reporting Rule (CROMERR). CROMERR is unique to EPA, and EPA is evaluating options that will both meet the CROMERR requirements and be acceptable to the user community. Will e-Manifest be real-time so I can check on the status of a shipment?EPA is evaluating technical options for the implementation of e-Manifest. At this time, the technical capabilities of e-Manifest are not yet fully defined.EPA does not envision providing the ability to track waste in real time; for example, users will not have the ability to see the exact geographic location of a shipment at all times during the shipping process. If information on the location of the waste becomes a requirement of the system, it is likely that EPA would only track the location and shipping status at each interval where the manifest is signed. Users of the system will be able to track this status of a shipment throughout the entire shipping process. EPA does not envision that the shipment status would be available to the public until the shipment is received and accepted by the treatment, storage, disposal facility (TSDF).
- EPA envisions that the e-Manifest system would contain data from all manifests, including paper manifests. The Hazardous Waste Electronic Manifest Establishment Act (The Act) includes authority for EPA to include, via rulemaking, such requirements that may be necessary to facilitate the transition from paper to electronic manifests, including accommodating the processing of data from paper manifests, and collecting reasonable service fees to recover the costs of processing paper manifests. As EPA evaluates the fee structure for e-Manifest, we will explore how to balance the cost of paper versus electronic manifests to ensure that EPA can recover the costs of processing the paper manifests.
- Will describe in further detail for generators, transporters and TSDFs in later slides.
- NPDES = National Pollutant Discharge Eliminiaton System
- The One Year Rule is the rule that EPA promulgated in order to comply with the Hazardous Waste Electronic Manifest Establishment Act, which required EPA to issue a regulation authorizing electronic manifests by October 5, 2013. In issuing this rule, EPA completed an important step that must precede the development of a national e-Manifest system, as required by the Hazardous Waste Electronic Manifest Establishment Act. This rule simply codifies several of the essential provisions of the Act, provides the legal and policy framework to authorize use of electronic manifests, and amends the existing manifest regulations to announce policy on electronic signatures and access to information (CBI). Will data be publicly available?EPA envisions that the data in e-Manifest will be made publicly available once a shipment is accepted by a TSDF and the data is verified. We recognize that hazardous waste shipments are live commercial transactions, and that manifest access should be restricted during the time that a shipment is in process. From the comments on the draft rule and other past notices, EPA recognizes that there may be some sensitivity about the aggregation of data collected from manifests and how aggregate data might be used for competitive purposes. EPA will be clarifying this issue in the ‘One Year Rule’ that is due to be published in October 2013.
- Although EPA has completed a major step in moving toward e-Manifest, hazardous waste handlers cannot begin tracking their hazardous waste shipments electronically until EPA establishes the e-Manifest system. The Act calls for the system to be online by October 5, 2015. Although EPA has not received appropriated funding to date for this program, it is making significant progress in establishing the groundwork for the system. As more information becomes available, EPA will post project schedule information on the e-Manifest web site. Milestones for EPA Actions: The Act requires that the e-Manifest Information Technology (IT) system must be up and running within three years after the Act is passed The EPA must issue regulation authorizing use of electronic manifests within one year after the Act is passed The EPA must establish a System Advisory Board within three years after the Act is passed in order to advise the EPA on system performance and user fees Next milestone is establishing fees and vendor contracts establishing the actual system details.
- When does EPA expect the system to be online?The Act calls for the system to be online three years from the signing of the Act. The Act was signed in October 2012, which means that the system should be online by October 2015. EPA is taking action now to meet the deadline. As with any Informational Technology (IT) project, there are significant unknowns that could affect the delivery date. As more information becomes available, EPA will post project schedule information on the e-Manifest web site.
- Not later tan 3 years after the date of enactment of the bill, the Administrator must establish a Hazardous Waste Electronic Manifest System Advisory Board. The composition of the board should be 9 members with one person serving as the Chairpoerson. The 8 remaining members will be appointed by the Admin and shall consist of at least 2 people who have expertise in information technology, 3 people who have experience in using or represent users of the manifest ssytem, and at least 3 people who are a state representiative responsible for processing the manifests. The board shall meet annually.
- The agency is up against an October 2015 statutory deadline to have the system operational, per the 2012 Hazardous Waste Electronic Manifest Establishment Act. The rule establishes the legal and policy framework for using e-Manifests. However, several more steps must be taken before the e-Manifest program can be fully implemented, namely working out the technical details of system design, operation, and security as well as the initial fee structure. EPA says it currently plans to host the e-Manifest system on EPA’s Central Data Exchange/National Environmental Exchange Network architecture, or something equivalent, thereby establishing a first-time national repository of manifest data that would be accessible by states and the public. Once the e-Manifest system is designed (most of the implementation details will be decided through the terms of a vendor contract), EPA will issue a second rule to establish the user fee schedule.
- he final rule decides the following issues: An electronic signature must be a legally valid and enforceable signature; and must be designed and implemented in a manner that EPA considers to be as cost-effective and practical as possible. Manifest information (including aggregated data) is not protected from disclosure as confidential business information. However, EPA will not make it available on-line until after 90 days, when it is considered to be a "complete and final document." This policy does not affect FOIA requests or State release of manifest information. Generators can "opt-out" of the electronic system. Also, generators can only use the electronic system for waste shipments if they know that all persons handling the shipment also will use electronic manifests. Even if the generator and transporter use paper manifests, the destination facility must provide the data from the paper manifest to the electronic system. A paper copy of the e-Manifest must be printed out and accompany the waste, thereby meeting DOT shipping paper requirements. The electronic manifest meets RCRA record retention requirements. If the electronic signature method used is undergoing a pilot or demonstration test, all parties must put an ink signature on the DOT shipping paper and that paper must be retained by the destination facility for 3 years. The e-Manifest system shall: (a) take effect in each state on the same date; (b) supersede any less stringent or inconsistent provision of a state program; and (c) be carried out by EPA in an authorized state except where the state has received final authorization for state program revisions implementing the electronic manifest requirements.
- How will the fees be set?The Act calls for EPA to set the initial fees via a rulemaking in consultation with IT vendor(s). This rulemaking is envisioned to take place in 2014. The initial fees will be set to cover not only operation and maintenance costs, but also the costs of developing the system. The Act also calls for the establishment of a Hazardous Waste Electronic Manifest System Advisory Board that consists of at least two people with expertise in information technology, three people with experience in using or representing users of the e-Manifest system, and three State representatives. The Act calls for this board to be established no later than October 2015. EPA will consult with this board to make adjustments to the fees once the board is established. Generators who want to use the e-Manifest system will be charged user fees and must ensure that all downstream waste handlers also agree to use the system.
- Some stakeholders have expressed concern about what the fee structure will look like and how the system will work. For example, the American Petroleum Institute believes the EPA’s e-Manifest system will require unnecessary recordkeeping and reporting and conflict with the U.S. Department of Transportation hazardous material requirements. (EPA acknowledges that it still will be necessary to carry a printed copy of the e-Manifest on the transport vehicle during the transportation of hazardous wastes that are subject to the hazardous materials regulations, 49 CFR parts 171-180 (HMR), thereby meeting DOT shipping paper requirements.)
- Under the Act, the scope of the e-Manifest system extends to both Federal RCRA hazardous wastes and to state-regulated wastes for which a manifest requirement is imposed under state law. Many states regulate additional wastes as hazardous or special wastes under their state regulatory programs, and the states may require shipments involving these non-RCRA wastes to be tracked with the hazardous waste manifest. To avoid the need for a separate tracking system for state-regulated wastes, the Act authorizes EPA to establish the national e-Manifest system to track the Federal RCRA and state-regulated wastes. Will States be permitted to require different or additional electronic manifests?No. The hazardous waste manifest is required to be a uniform shipping document under both RCRA and the hazardous materials transportation laws. Since 2006, EPA has required the use of a Uniform Manifest form that precludes state variations, other than tracking states’ additional wastes subject to the manifest, and entering state waste codes and facility ID numbers that are not redundant with RCRA waste codes and ID numbers. The electronic manifest will operate in the same manner, and EPA and the national e-Manifest system will support only the uniform electronic manifest format that EPA will establish as the national standard once the e-Manifest is implemented. States will be precluded from requiring different or additional formats or requirements.
- ‘‘(h) REQUIREMENT OF COMPLIANCE WITH RESPECT TO CERTAIN STATES.—In any case in which the State in which waste is generated, or the State in which waste will be transported to a designated facility, requires that the waste be tracked through a hazardous waste manifest, the designated facility that receives the waste shall, regardless of the State in which the facility is located— ‘‘(1) complete the facility portion of the applica- ble manifest; ‘‘(2) sign and date the facility certification; and ‘‘(3) submit to the system a final copy of the manifest for data processing purposes.’’.
- As more details on e-Manifest become available, this list will expand. Make sure you check back to see the most current list of recommendations.
- TSDF = treatment, storage, disposal facility It is currently envisioned that a generator would see several benefits from e-manifest, including the ability to fill out manifests online, using drop-downs and pre-populated forms. Generators would also be able to track their shipments and receive confirmation on delivery and acceptance. E-Manifest would also help the generators in meeting some of their recordkeeping requirements in relation to manifests.Here are a number of key things that you can do as generators to make sure that you’re ready for e-Manifest:Get Involved: In order to ensure that e-Manifest integrates into your business process, you can start now by making sure that EPA understands your business process, including any data systems that you currently use for tracking hazardous waste and for generating manifests. Participate in one of EPA’s system requirements meetings or webinars either directly or through a trade association.Talk to your transporters and TSDFs: Since e-Manifest integrates the tracking of manifests across many parties, it is important that you communicate with your transporters and TSDFs to determine how they intend to implement e-Manifest as EPA releases more information on the design of the system. In many cases, the transporter will supply the technology with which generators will participate in e-Manifest.Check the e-Manifest website regularly: New information will be posted to the e-Manifest website as it becomes available. The best way to stay informed will be to check the website regularly.As more details on e-Manifest become available, this list will expand. Make sure you check back to see the most current list of recommendations.
- EPA recognizes that transporters are a key client of the e-Manifest system. For example, it has always been envisioned that e-Manifest would be able to support mobile devices, and these mobile devices will most often be carried on transport vehicles so that the e-Manifest can provide cradle-to-grave tracking services. This is of particular importance to the transporters. E-Manifest would eliminate the need for the current 6-page paper manifest; however there may still be some minimal need to carry paper in order to support DOT requirements.Here are a number of things you can do as transporters to make sure that you’re ready for e-Manifest:Get Involved: In order to ensure that e-Manifest integrates into your business process, you can start now by making sure that EPA understands your business process, including any data systems that you currently use for tracking manifests. Participate in one of EPA’s system requirements meetings or webinars either directly or through a trade association. You should pay particular attention to any discussion around the electronic signature requirements for e-Manifest.Talk to your generators and TSDFs: Since e-Manifest integrates the tracking of manifests across many parties, it is important that you communicate with your generators and TSDFs to determine how they intend to implement e-Manifest as EPA releases more information on the design of the system.Check the e-Manifest website regularly: New information will be posted to the e-Manifest website as it becomes available. The best way to stay informed will be to check the website regularly.As more details on e-Manifest become available, this list will expand. Make sure you check back to see the most current list of recommendations.
- TSDF = treatment, storage, disposal facility EPA is seeking to learn as much as we can about the current business process that TSDFs use for providing and tracking manifests. EPA views TSDFs as a key customer of the e-Manifest system.Here are a number of things you can do as TSDFs to make sure that you’re ready for e-Manifest:Get Involved: In order to ensure that e-Manifest integrates into your business process, you can start now by making sure that EPA understands your business process, including any data systems that you currently use for tracking manifests. Participate in one of EPA’s system requirements meetings or webinars either directly or through a trade association.Talk to your generators and transporters: Since e-Manifest integrates the tracking of manifests across many parties, it is important that you communicate with your generators and transporters to determine how they intend to implement e-Manifest as EPA releases more information on the design of the system.Check the e-Manifest website regularly: New information will be posted to the e-Manifest website as it becomes available. The best way to stay informed will be to check the website regularly.As more details on e-Manifest become available, this list will expand. Make sure you check back to see the most current list of recommendations.
- The rail industry currently operates an electronic waybill system that enables rail shippers and carriers to track the location and status of hazardous materials shipments that move on the rail system. While EPA’s primary focus in developing e-Manifest is to facilitate the tracking of hazardous wastes that are shipped over the highway, the Agency, through its requirements gathering process, plans to coordinate with the rail industry so as to reduce the burden that the rail industry currently incurs in receiving paper manifests at rail offices, manually entering manifest data into the waybill system, and forwarding the remaining manifest forms by mail to the next RCRA handler.
- This document describes the e-Manifest system's high level architecture and design approach, and how data will flow through the system. Aspects of this document are subject to change. EPA will be hosting outreach/communications webinars and/or meetings in FY 2014 with relevant stakeholders to discuss technical architecture design and related issues. There are some IT consultants who are trying to get ahead of the curve and offer software solutions to industry that will support waste management and reporting needs and incorporate the future regulations.
- Careful when you look online, a simple search for “eManifest” brings up a Canada Borders Services Agency program after the first link which is the US EPA website. Search eManifest EPA for best results!
- The purpose of the e-Manifest ListServ is to provide an open forum for the posting and discussion of news and information relating to the e-Manifest program. EPA will use this listserv to provide stakeholders with system and program announcements and updates. For example, when information changes on EPA’s e-Manifest website, a note will be sent out to the ListServ. This Listserv can also be used to facilitate e-Manifest conversations amongst the stakeholder and user community. Please note the code of conduct for the ListServ that is included in the welcome email you receive once you subscribe.Here are directions for joining and using the e-Manifest ListServ:SUBSCRIBE: Send a blank message to: eManifest-subscribe@lists.epa.gov. Once your email is subscribed to the list, you will receive a welcome email indicating you are a member. After that, you are able receive any messages sent to the list, as well as contribute messages to the list.CONTRIBUTE TO THE LIST: Send a message to: eManifest@lists.epa.gov.UNSUBSCRIBE: Send a blank message to: eManifest-unsubscribe@lists.epa.gov.