EPA’s new electronic hazardous-waste tracking system does not force waste generators to stop signing paper manifests. The agency launched e-Manifest nationwide on June 30, 2018, but generators can keep using paper. Receiving facilities must submit the manifests to EPA, whether the shipment started on paper or electronically. For businesses arranging hazardous-waste disposal, the immediate choice is how the paperwork moves between the generator, hauler and receiving facility. [S1][S2][S3]
EPA’s June guidance for treatment, storage and disposal facilities describes a hybrid route. A manifest is created in e-Manifest, then printed and signed on paper by the generator and initial transporter. That signed copy stays with the generator. The initial transporter, any later transporters and the receiving facility sign electronically as the shipment proceeds. A generator can therefore retain a paper signature while the downstream chain uses the electronic system. [S3]
Going fully electronic requires more than a generator opening an account. EPA’s May generator guidance says the generator needs an EPA identification number, and the transporters and receiving facility listed on the manifest must also be registered. Each user registers separately; electronic signers undergo identity proofing and use a compliant electronic signature. A generator choosing electronic manifests therefore needs to coordinate with its disposal providers, not just change its own office procedure. [S2]
The fee incentive sits with the receiving facility. EPA charges that facility according to the submission method: mailed paper carries the highest fee, scanned-image and data-plus-image submissions carry intermediate fees, and electronic manifests, including hybrids, carry the lowest. That gives the receiving facility a reason to encourage electronic handling even when the generator keeps a paper signature. The guidance does not establish what a disposal company will charge an individual customer. [S1][S3]
Keeping paper also leaves a copy-return job to arrange. EPA says generators without e-Manifest accounts should work with their receiving facilities to obtain completed paper manifests for their records. The system supplies electronic copies only to registered generators with accounts. The generator still needs the completed record, not just the copy signed when the shipment starts. [S2][S3]
The first paper submissions get extra time. Although the earlier fact sheets specify submission within 30 days of receipt, EPA’s July 2 announcement says receiving facilities have until September 30, 2018, to send paper manifests for waste received between June 30 and September 1. That is an initial submission extension for receiving facilities, not a requirement for generators to abandon paper. [S1][S2][S3]
Source documents
- EPA Launches e-Manifest National Electronic Hazardous Waste Tracking Systemhttps://www.epa.gov/archive/epa/newsreleases/epa-launches-e-manifest-national-electronic-hazardous-waste-tracking-system.html
- e-Manifest Fact Sheet: Generators — May 2018https://www.epa.gov/sites/default/files/2018-05/documents/e-manifest_generators_fact_sheet_0.pdf
- e-Manifest Fact Sheet: TSDFs — June 2018https://www.epa.gov/sites/default/files/2018-05/documents/r7-e-manifest-fact-sheet-tsdf-may-2018.pdf