EPA Final Rule: Electronic Hazardous Waste Manifest User Fees

[Update 10/01/2019]
Increased e-Manifest User Fees took effect on October 1, 2019. 

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In an important step toward establishing an electronic system of  tracking hazardous waste shipments—the electronic Manifest or “e-Manifest” system—US EPA today posted a Final Rule detailing how the Agency will assess fees to users of the system.

In addition to establishing the fees, the Final Rule modifies EPA’s proposed e-Manifest rules to allow changes to the transporters designated on the Manifest while the shipment is en route, to describe how corrections can be made to existing Manifest records in the system, and to allow for a mixed of paper and electronic Manifests to track a shipment in certain instances.

In addition to wastes covered under Federal regulations, many State-only hazardous wastes also require the use of the hazardous waste Manifest for transport. In all, EPA estimates 80,000 Federally regulated generators, transporters, and treatment facilities go through three to five million Manifests each year.

Who Will Pay? And How Much?

EPA has determined that charging user fees to treatment, storage, and disposal facilities (TSDFs) and State-only waste receiving facilities is “the most effective and efficient means” of collecting user fees to fund the administration of the e-Manifest system.

While no contracts are in place to set up or host the e-Manifest system yet, EPA has projected the fees for the first year in operation as between $4 and $20, depending on the type of Manifest used (a paper Manifest being most expensive).

What Is the Hazardous Waste Manifest?

The Uniform Hazardous Waste Manifest is the primary shipping document used to track hazardous waste from the facility at which it was generated to its eventual disposal. These records provide facilities and transporters with proof that hazardous waste was delivered to an authorized location for proper disposal, as required under the Resource Conservation and Recovery Act (RCRA).

Don’t be fooled! While the Manifest is an EPA document, hazardous waste shipments are regulated in transport by the US DOT under the Hazardous Materials Regulations (HMR). This means that personnel who prepare hazardous waste shipments, and anyone who signs the Hazardous Waste Manifest, must complete hazmat training per 49 CFR 172.704.

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Tags: EPA, hazardous waste, manifest, RCRA, reporting and recordkeeping