Posted on June 21, 2021 by Robert Clarke. CDGP
Starting June 30, 2021, US EPA will no longer accept paper manifests from hazardous waste receiving facilities (i.e., TSDFs).
Moving forward, receiving facilities must use one of the following methods to submit manifest data into the e-manifest system through the
online RCRAInfo portal:
- Electronic
- Hybrid
- Image only
- Data plus image
How Will the Deadline Impact Generators?
Because receiving facilities now must submit manifests to EPA electronically, TSDFs may request that generators create an account in the online system.
Some generators may not feel the impact right away. Some TSDFs may continue to accept paper manifests and then manually transfer the required information into the e-manifest system using the image upload or data-plus-image upload option. These alternatives are
more expensive than the fully electronic option.
When the e-Manifest system launched on June 30, 2018, EPA had stated that it intended for generators to adopt e-Manifests within five years. Given the slow adoption of e-Manifests so far, the agency has since softened its position about generators.
At this time, EPA has not set a hard deadline or sunset date for generators to stop using paper and start using e-Manifests.
e-Manifest Usage Up Slightly
About 3% of the manifests that EPA receives are submitted in paper format, as of late April 2021.
0.5% of all manifests are completed entirely online.
That’s an improvement. At the end of February 2020, EPA was receiving 4.4% of all manifests in paper form, and only 0.3% of manifests were created "fully electronic." Use of the electronic hazardous waste manifest system is increasing, but is still far below what EPA hoped when it finalized the e-Manifest Final Rule.
Despite the slow adoption of the new tool, the vision of a fully electronic system to track shipments of hazardous waste is alive and well.
Learn more about the e-Manifest system at EPA's website.
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