Lion's office will be closed at 3:30 PM ET on Friday, May 23 and all day on Monday, May 26. Online training support is available from 8:30 AM to 5 PM ET. Contact support@lion.com.
Search

E-Manifests and 49 CFR: Paper Copies Still Required

Posted on 6/18/2019 by Joel Gregier, CDGP

Currently, one of the biggest topics in the hazardous waste world is the use of electronic manifests, or e-manifests.  As of June 30, 2018, shippers of hazardous waste can now start using e-manifests to document their waste shipments.

The e-manifest system, which is done using EPA’s RCRAInfo site (rcrainfo.epa.gov), has many benefits. One of them is that we no longer need physical hard copies of manifests to accompany the shipment.  But just because the EPA is fine with no paper copy, the same is not true for the Department of Transportation (DOT).

Keep your hazardous materials transport expertise up to date when expert-led hazmat workshops come to New Jersey, Philadelphia, Boston, Hartford, Atlanta, Charlotte, Nashville, Jacksonville, and Orlando in Summer 2019!  

DOT Still Wants Paper Copies for Safety Reasons

The Uniform Hazardous Waste Manifest form has been used for decades to meet both EPA and DOT documentation requirements when shipping hazardous waste.  As such, each agency has certain sections of the manifest that they use to convey certain bits of information.

On the DOT side of things, the manifest (or any other hazmat shipping document) is meant to provide safety information to the carriers moving the hazmat (such as truck drivers), but also to emergency response providers in the case of an accident.  As such, the DOT wants to make absolutely sure that this safety information is available.

At this point in time, the DOT’s opinion is that an actual paper copy is still the safest bet for providing the information.  For instance, what happens if there’s no cell phone signal in range?  How are you supposed to pull up the manifest from the RCRAInfo site?  Also, what happens if the battery dies on the carrier’s tablet or computer?  So for now, the DOT still requires paper copies.

How to Provide Paper Copies of the Manifest

There are two scenarios currently for how to provide paper copies of the manifest: one using the new e-manifest system and one using the traditional method.

Currently, e-manifests are voluntary.  Generators can still choose to completely use paper manifests from the get-go (and in fact, most manifests are still being shipped by NOT taking advantage of e-manifest).  If a shipper decides to go this route, they would use a paper form that consist of five copies.  This would need to be purchased from an authorized manifest provider.

If the generator chooses to start using e-manifests now, providing a copy of the shipping document is fairly simple.  They would simply print out a single copy from the RCRAInfo site.  DOT does allow this as they now allow electronic signatures specifically for e-manifests.  This is one of the rare times the DOT actually allows an e-signature.

Can I Use E-manifests for Paperwork Retention?

The DOT requires all shippers of hazardous wastes to retain their manifests for at least three years. The good news is that the DOT allows documentation to be kept as an electronic image as long as the shipping paper can be made available upon request to government agents at reasonable times and locations.

One of the benefits of using e-manifest is that a copy is automatically saved to RCRAInfo.  As such, the shipper is already meeting the retention requirements for the DOT since a saved copy already exists.

The DOT May Eventually Allow Fully Electronic Manifests

Just because the DOT does not allow fully electronic manifests now does not mean that this will never be allowed.  The DOT is having ongoing talks with the EPA as well as other affected parties about possibly altering their rules in the future. 

However, as with all things government related, do not expect the change to happen next week. Lion staff will continue to monitor DOT and EPA discussions about hazardous waste shipments, and report back on any developments or rule changes.

Nationwide Hazmat Training in Summer 2019

Join expert Lion instructors in cities nationwide for engaging, comprehensive hazardous materials training to help you simplify your responsibilities and maintain compliance with 49 CFR, the IATA DGR, and the IMDG Code.

Catch the Complete Multimodal Hazmat Shipper Workshops near you this summer:
Parsippany, NJ July 8—11
Hartford, CT July 15—18
Atlanta, GA July 30—Aug. 2
Nashville, TN Aug. 5—8
Jacksonville, FL Aug. 13—16
Plus, catch 49 CFR and/or IATA DGR training for hazmat ground and air shippers in Boston, Philadelphia, Williamsburg, Baltimore, Charlotte, and Orlando throughout July.

 

Tags: e-manifests, hazardous materials, hazardous waste shipping, hazmat shipping, new rules

Find a Post

Compliance Archives

Lion - Quotes

Lion courses always set the bar for content, reference, and practical application. Membership and access to the experts is an added bonus.

John Brown, CSP

Director of Safety & Env Affairs

The instructor was very engaging and helped less experienced people understand the concepts.

Steve Gall

Safety Leader

Excellent course. Very interactive. Explanations are great whether you get the questions wrong or right.

Gregory Thompson

Environmental, Health & Safety Regional Manager

I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for.

Frank Sizemore

Director of Regulatory Affairs

Given the choice, I would do all coursework this way. In-person courses go very fast without the opportunity to pause or repeat anything.

Ellen Pelton

Chemical Laboratory Manager

One of the best trainings I have ever received!

Brandon Morfin

EH&S Manager

I used the IT support number available and my issue was resolved within a few minutes. I don't see anything that could have made it better.

Danny Province

EHS Professional

The instructor was excellent. They knew all of the material without having to read from a notepad or computer.

Gary Hartzell

Warehouse Supervisor

Lion was very extensive. There was a lot of things that were covered that were actually pertaining to what I do and work with. Great Job. I will be coming back in three years!

Tony Petrik

Hazmat Shipping Professional

The instructor took a rather drab set of topics and brought them to life with realistic real-life examples.

Tom Berndt

HSE Coordinator

Download Our Latest Whitepaper

Just starting out with shipping lithium batteries? The four fundamental concepts in this guide are the place to start.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.