Hazardous Waste e-Manifest System Coming in June
EPA is establishing a nationwide electronic hazardous waste tracking system, and it hopes to have it up and running by June.
EPA is establishing a nationwide electronic hazardous waste tracking system, and it hopes to have it up and running by June. The system will be known as e-Manifest, and will allow shippers to complete electronic manifests and destination/receiving facilities the opportunity to electronically upload manifests. All states will be required to implement e-Manifest and incorporate it into their hazardous waste programs as an option. The system will be linked to RCRAInfo, a separate site which collects information on hazardous waste sites.
⚡ TL;DR: EPA’s e-Manifest system links to RCRAInfo and enables electronic hazardous waste manifests with e-signatures. Electronic manifests satisfy EPA, RCRA, and DOT recordkeeping requirements. Fees are per manifest and lower than paper manifests.
Right now, using e-Manifest is optional. Paper manifests will still be accepted from generators for the foreseeable future, and from destination/receiving facilities for up to three years. EPA hopes that by using electronic means, significant gains in cost, time, accuracy, notification, and monitoring effectiveness can be realized by all who use the system. Electronic manifests will be just as legal as paper ones, except they’ll be completed and signed electronically.
Using e-Manifest will satisfy EPA, RCRA and DOT 3-year recordkeeping requirements. EPA is also working with DOT to ensure e-Manifest will produce a proper shipping paper. DOT will still be requiring hard copies to be sent with the shipment, so those using e-Manifest will be able to print out a copy of their manifest for DOT purposes.
⚠️ What’s at stake: Incomplete or late manifest submissions trigger EPA enforcement. Loss of manifest records creates liability for waste tracking compliance and exposes generators to enforcement action.
In the future, the e-Manifest system may link to the Biennial Hazardous Waste Report, and potentially replace it. The fees for the system will be paid by the destination or receiving facility, which more than likely will be passed down to the generator.
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Frequently Asked Questions
Q: What is EPA’s e-Manifest system and how does it replace paper hazardous waste manifests?
EPA’s e-Manifest is a nationwide electronic hazardous waste tracking system allowing shippers and destination/receiving facilities to complete and upload hazardous waste manifests electronically. Electronic manifests are legally equivalent to paper manifests and require electronic signatures. All states are required to implement e-Manifest as an option within their hazardous waste programs, though paper manifests currently remain accepted from generators.
Q: Is e-Manifest mandatory for hazardous waste generators and transporters?
Currently, using e-Manifest is optional, and paper manifests remain accepted from generators indefinitely. Destination/receiving facilities may use paper manifests for up to three years. EPA encourages electronic manifest use to achieve improvements in cost, time, accuracy, notification, and monitoring effectiveness for all users in the hazardous waste system.
Q: How does e-Manifest relate to EPA’s RCRAInfo system and DOT shipping requirements?
E-Manifest is linked to RCRAInfo, which collects information on hazardous waste sites. Electronic manifests satisfy EPA, RCRA, and DOT three-year recordkeeping requirements. Users can print copies of electronic manifests for DOT purposes since DOT still requires hard-copy shipping papers to accompany shipments containing hazardous materials.
Q: Who pays the fees for e-Manifest and how are they structured?
E-Manifest fees are charged per manifest and paid by the destination or receiving facility, which typically passes costs to generators. Electronic manifest fees are lower than paper manifest fees. In the future, EPA plans to potentially link e-Manifest to the Biennial Hazardous Waste Report and may eventually replace paper reporting requirements.
💰 The cost of non-compliance: Missing manifest deadlines or recordkeeping failures trigger EPA civil penalties of $25,000-$50,000+ per violation. Hazardous waste tracking failures can result in criminal charges.
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