Hazardous Waste e-Manifests: Making the Switch
But the dilemma that many are facing right now is whether they should make the switch from paper manifests to e-manifests.
You Can Make the Switch NowGenerators of hazardous waste have always needed to ship their hazardous waste on a Uniform Hazardous Waste Manifest. This allows both the EPA and the Department of Transportation (DOT) to document these shipments and ensure they are being delivered appropriately to their destination, which is typically a Treatment, Storage, and Disposal Facility (TSDF).
With the creation of e-manifests, generators can now do this fully electronically. This is done through EPA’s RCRAInfo site (RCRAInfo.epa.gov). There are many benefits to using an e-manifest: more timely and accurate data on the manifests, cost savings, paperwork reduction, and a “one-stop” location to store all manifest data.
But while generators can now create e-manifests, some logistical challenges remain that may make it difficult to move away from paper manifests.
Everyone Has to Be on BoardBefore you can create an e-manifest, everyone in the manifest chain must be using the new system. What that means is that everyone has to be registered with the site. Even if you are signed up as a generator, unless your transporter and your TSDF are also registered with RCRAInfo, you cannot use e-manifests.
In fact, TSDFs are a major roadblock in the transition to e-manifests. Many have decided not to make the switch yet because they are hesitant to change their standard operating procedures. If it’s not broken, why fix it?
So at the moment, even if you want to use e-manifests, you will not be able to until your TSDF decides to join in.
Do you sign the hazardous waste manifest? Keep your DOT hazmat training up to date with the Hazmat & Waste Ground Shipper Certification Online Course. US DOT requires hazmat training for everyone who affects the safety of hazardous materials—including hazardous waste—in transportation (49 CFR 172.704).
DOT Still Requires a Paper CopyIn addition to the EPA, the US DOT also uses manifests as hazmat shipping papers. But at this point in time, the DOT does not allow a fully electronic shipping document. So, if you decide to switch over to the e-manifest system, you’ll still be required to print out a copy to go along with your shipment. As a result, a lot of hazardous waste shippers have decided to just stay with paper copies.
To learn more about DOT’s implementation of e-manifests, check out one of our previous posts about this topic: E-Manifest and 49 CFR: Paper Copies Still Required.
Am I Still Allowed to Use Paper Manifests?Although EPA would like you to use e-manifests immediately, at this point, the Agency does not require the use of one. You are permitted to continue using paper copies—for now.
EPA does plan to phase out paper manifests over time. TSDFs have three years from the implementation date to start using RCRAInfo (June 30, 2021). Generators have five years (June 30, 2023).
To avoid a scramble when your transition deadline hits, starting the process of switching sooner than later is a good management practice, even given that you still must print a copy to meet DOT hazmat shipping paper requirements. If you wait until the last minute to join the e-manifest party, you could find yourself in a situation of non-compliance, as switching to e-manifests will probably not be an overnight change. You will make your life a lot easier if you don’t procrastinate on this.
If you do prefer to continue using paper manifests, make sure you are still purchasing them from an authorized manifest printer.
DOT Hazmat Training to Sign the ManifestWhen you sign hazmat shipping papers or the Hazardous Waste Manifest, you certify that the shipment is in full compliance with all applicable hazardous materials requirements—from classification and naming to packaging, marks, labels, placards, and more. To do this with confidence, you need a strong background in the 49 CFR Hazardous Materials Regulations (HMR).
The Hazmat & Waste Ground Shipper Certification Online Course is used by shippers nationwide to develop a complete understanding of the regulations for shipping hazardous materials and waste. Online hazmat training makes it easier to fit learning into your schedule, without putting your operations on hold. Start and stop as needed throughout the course and download resources that simplify compliance—including relevant sections of the 49 CFR regulations.
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