June 29, 2018
US EPA has announced the e-Manifest System will be launched on June 30th. This system promises to change the way we manage not only manifests for shipments, but also all information related to the generation, treatment, transportation, and disposal of hazardous wastes. However, at this time significant components of the system remain under development by the agency. This prevents a wholesale switch to electronic manifest management. Most of the hazardous waste disposal facilities we work with have advised us that for the time being, they intend to continue to prepare paper manifests.
According to the EPA website: “It is not required that generators register for e-Manifest by June 30, 2018. Generators who are not registered in e-Manifest can continue to use paper manifests, as they do under the existing paper-based manifest system, or under the hybrid manifest scenario.
Eventually, and over time, generators will need to register for e-Manifest if they wish to sign manifests electronically in the system, view manifest records in the system, or if they want the ability to submit post-receipt data corrections to the manifest” (source).
EPA has clarified that while there will be a fee associated with the e-Manifest System, that fee will be assessed to the destination or receiving facilities. EPA has not imposed fees on generators to use the System. We anticipate that most disposal facilities will pass these fees along in your invoice for waste disposal. You will not be required to make payments directly to EPA.
Therefore at this time, EWI recommends continuing to complete hazardous waste manifests in paper or pdf form. We will then work with the disposal facilities to upload electronic copies of the completed documents, as necessary to comply with e-Manifest requirements. Some states will continue to require generators to submit copies of the manifests and to comply with the three-year document retention period for paper manifests.
We anticipate that EPA will complete the programming necessary for full electronic management in the near future. We are continuing to monitor the progress of this e-Manifest System and will post updates here as we become aware of progress by the agency and changes in practices of disposal facilities.
For more information on the e-Manifest System, visit the US EPA website at https://www.epa.gov/e-manifest.