Who's Using Electronic Manifests?
But as reality has now set in for about a year and a half, it’s become abundantly clear that people have not switched over yet. There’s some partial adoption, but the full adoption that the EPA had hoped for has not happened yet.
Who's Using E-Manifests?Below is a pie chart sourced directly from the EPA’s most recent monthly webinar, dated February 26, 2020. According to their 2020 numbers, 663,754 manifests have been submitted to the EPA. However, only 1,838 of those manifests have been submitted fully as an electronic manifest, or e-manifest. That is less than 0.3% of all submitted manifests.
As you can see from the chart, the vast majority of manifests are being submitted as “Data+image,” which means they started as a paper manifest and were later uploaded into the e-manifest database as an image.
So why the lack of adoption of e-manifests?
Everyone Has To Buy In FirstThe way e-manifest works, all manifests must be submitted to RCRAInfo, which can be found at the RCRA info website. The entities that make the final submission are the “receiving facilities,” which is almost always the Treatment, Storage, and Disposal Facility (TSDF).
But for a manifest to be submitted fully electronically, every person in the chain must be registered and using the site. That means the generator, transporter, and TSDF all have to be using RCRAInfo to create an e-manifest. If one person in that chain refuses to use e-manifest, then it forces all the others to revert to paper manifests.
Aversions to Switching OverThere’s no one entity that is fully at fault for not adopting the new e-manifest system. But justifications range from:
- “We have to update all our software to meet the new requirements,”
- “We have too many employees to register for the site in a timely manner,”
- “All of this seems confusing/intimidating to me and we do not know what to do,”
- “Paper manifest worked just fine so why should we have to switch,”
- “We are waiting until the last minute to switch over” (a.k.a. procrastination), or
- “We did not even realize RCRAInfo/e-manifest exists.”
You Will Have to Switch to e-Manifest Eventually
Whatever reason your company is choosing to not fully adopt e-manifest yet, it will eventually have no choice. With the new system, the EPA will require all regulated persons to submit electronically using the following timetables:
- “Receiving facilities” by June 30, 2021 (3-year transition)
- “Generators” by June 30, 2023 (5-year transition)
The good news is that, contrary to what you may believe, RCRAInfo is actually a fairly easy site to use. In fact, once everyone finally transitions to e-manifest, it should be easier, more efficient, and less costly to use e-manifest as compared to their paper counterpart. And as an added benefit, it should be better for the environment with everything being done digitally.
RCRAInfo Is Fairly Easy to Use
But if you choose to wait until the last minute, it will make the transition much more difficult. So at least as a starting point, why not at least try and register with the site to get the ball rolling?
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