RCRA Compliance Advisory on E-Manifest Data Errors

Posted on 3/20/2023 by Roger Marks

US EPA issued a Compliance Advisory earlier this month to remind hazardous waste generators and receiving facilities about the requirements for complete and accurate manifests to track shipments.

Since receiving the first manifests in electronic format, EPA has identified three issues with the completeness and accuracy of the data submitted.

When entering hazardous waste manifest data to the electronic system, the receiving facility must certify that the data submitted is accurate and complete. In the Advisory issued on March 14, EPA warns that enforcement action may be taken against facilities who submit incomplete or inaccurate data through the e-Manifest system.

RCRA Compliance Advisory on E-Manifest Data Errors

3 Common Data Errors on E-Manifests

1. An inaccurate or missing EPA ID number, including for small and very small quantity generator sites. 

Generally, VSQGs are exempt from using the manifest and participating in the e-Manifest system (though EPA encourages everyone to participate). A few situations require a VSQG to obtain an EPA ID number, however— like a state requiring a manifest for “non-RCRA” waste or a VSQG using the exemption for episodic events (in states that adopted these provisions).

If a VSQG has obtained an EPA ID number, it must be included on the manifest. 

2. Mis-matching or invalid Manifest Tracking Numbers (MTN) 

Each manifest is printed with a unique tracking number on it. Generators may only use hazardous waste manifests printed by an approved and registered vendor—of which there are a limited number. Every manifest is printed with a unique tracking number and may only be printed by an approved and registered vendor.  

EPA has received manifests with tracking numbers that are not valid, as well as electronic submissions that use a MTN that does not match the hard copy of the manifest. 

3. Electronic submission & typo errors

The third issue EPA identifies is that data entered through the electronic system is sometimes incomplete or inaccurate because the user who entered the data either mis-typed something or could not read the writing on a paper manifest.

See the full Compliance Advisory and more information about the e-Manifest program for hazardous wastes (and other substances) on EPA's website.

hazardous waste container with hazard labels

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Tags: electronic manifest, e-manifest, hazardous waste, RCRA

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