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).
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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.
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