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e-Manifest System: What You Need to Know

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Launch of the e-Manifest 

For years the Environmental Protection Agency (EPA) has been working toward establishing a national system for tracking hazardous waste manifests electronically. This system, known as "e-Manifest" was created under the Resource Conservation and Recovery Act (RCRA) to launch June 30th, 2018.

It has been the EPA’s goal for all handlers of hazardous waste manifests to be creating and submitting manifests electronically on the e-Manifest system by that date. While the set launch date will be upheld, the goal of every hazardous waste handler being on a single manifest system that day will not. 

Paper Manifests: Exist and Can Still Be Used

To ease transition into using the e-Manifest system, the EPA has already decided to take a step back from the idea that all manifests will be electronic on June 30th, making clear months ago that use of the paper manifest will be allowed for several more years. The manifest regulations require receiving facilities accepting a shipment accompanied by a paper manifest to submit the manifest to the EPA within 30 days of receipt by either:

  • Mailing it to the EPA.

  • Uploading image files (e.g. Adobe PDF files)

  • Uploading data files (e.g. JSON file with an image file attachment.)

Updated Paper Manifest Format

Regulations still require all waste handlers (generators, transporters, and receiving facilities) to keep records evidence the signatures of each of party involved in the chain of custody. While paper manifests may still be used, there’s a new manifest form that consists of 5-copies rather than 6. In its Form 8700-22, though, the EPA indicated this new 6-copy form will likely not be available for use on most printers until September 1, 2018.

Can Your 6-Copy Manifests Still Be Used?

The EPA confirmed existing 6-copy manifests can still be used, provided distribution information specified on the top copy of the 5-copy edition is added to the top copy of the 6-copy. That information, in the lower right-hand corner of the top copy, reads, “Designated Facility to EPA’s e-Manifest System.” When it comes down to 5 or 6-copies, the EPA has no preference. The intent is to minimize confusion and provide the most seamless transition possible. 

Additional e-Manifest Information

Regardless of the method selected for interim use, treatment, storage, and disposal facilities (TSDFs) must begin using electronic manifests within three years, and generators must get on board within five. In other words, e-Manifests are coming, and if you need advice on how to best make this transition, the sooner you contact an environmental professional the better.

If you need consultation on how to best prepare for the new system, contact August Mack Environmental to speak with one of our experienced environmental professionals. For updates on most recent developments on the e-Manifest system, visit the EPA’s website using this link or see a full layout of the system presented in a recent EPA webinar here

Post Date: 6/29/2018



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