Available Now: 2023 Schedule of Hazmat & RCRA Training
Search

EPA Moves Forward with e-Manifest Standards

Posted on 5/27/2014 by Won Bae

On February 7, 2014, the US EPA established a new set of rules (79 FR 7518) for the e-manifest system. This system is meant to provide an alternative method of tracking hazardous waste shipments from generators to treatment, storage, and disposal facilities (TSDFs). While the EPA has a long-term goal of tracking hazardous waste electronically, the e-manifest system will coexist with paper manifests for years to come. Today, the e-manifest rule is still in its infancy since there are parts of how this new rule would be implemented that remain unfinished.
 
Although the new rule is effective starting August 6, 2014, the use of the e-manifest will not be permissible until the EPA actually creates the IT system for it. The system is still under construction, and the date of finalization has not been determined. Once determined, there are just a few conditions that would have to be met in order for the system to work. However, having a working e-manifest system in place won’t mean that paper documents will go away.
 
Meeting DOT (49 CFR) Shipping Papers Requirements
 
In order to make use of the e-manifest, all waste handlers, that is, the generator, transporter, and TSDF, would need to participate in the e-manifest system. However, the generator would still need to provide a paper copy of the manifest to the initial transporter of the hazardous waste. In other words, the DOT will not recognize the electronic copy of the manifest to be the sole shipping paper.
 
e-Manifest’s Effect on Other RCRA Requirements
 
The e-Manifest rulemaking will not impact other reporting and recordkeeping requirements under RCRA. LDR notices and certifications, exception reports, export acknowledgements, discrepancy reports, and notifications of waste activity will continue to be recorded and submitted on paper documents for the foreseeable future.
 
Electronic Signatures on e-Manifests 
 
Since the e-manifest IT system has yet to be created, another aspect of the e-manifest that remains uncertain is the requirement of an “electronic signature.” The February 7 rulemaking states that an electronic signature will be required to authorize the transfer of hazardous wastes from one handler to the next. The EPA stated in the proposed rule’s preamble that the signature validation method will be governed by the definition of “valid signature” under the Agency’s Cross-Media Electronic Reporting Regulation at 40 CFR 3. 
 
Using the e-Manifest for State Hazardous Waste
 
When the generator’s state or the destination state of a hazardous waste shipment requires the use of the manifest, generators may use the e-manifest system as long as all the waste handlers are participating in the e-manifest system. Waste handlers have to keep in mind that users of the e-manifest system may opt out and return to the original paper system at any time.
 
Finally, the EPA plans to establish a fee system for persons using the e-manifest. The actual fee structure has yet to be established. Future rulemakings are on the horizon, but until then, some elements of the new system remain unclear.
 
Renew your RCRA certification for 2014 at the Hazardous/Toxic Waste Management Workshop. The interactive two-day workshop covers the rules for managing and storing waste on site, manifesting, and more. Be confident that you and your team are prepared to meet your legal responsibilities to prevent accidental releases, fines as high as $37,500 per violation, and future liability under CERCLA. The US EPA requires training annually for hazardous waste personnel. [40 CFR 262.34(a) and 265.16] 

Tags: DOT, hazardous waste, manifests, new rules, RCRA

Find a Post

Compliance Archives

Lion - Quotes

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

This is the best RCRA training I've experienced! I will be visiting Lion training again.

Cynthia L. Logsdon

Principal Environmental Engineer

The workshop covered a lot of information without being too overwhelming. Lion is much better, more comprehensive than other training providers.

George Alva

Manufacturing Manager

The instructor was probably the best I ever had! He made the class enjoyable, was humorous at times, and very knowledgeable.

Mary Sue Michon

Environmental Administrator

Having the tutorial buttons for additional information was extremely beneficial.

Sharon Ziemek

EHS Manager

Lion's training was by far the best online RCRA training I've ever taken. It was challenging and the layout was great!

Paul Harbison

Hazardous Waste Professional

I can take what I learned in this workshop and apply it to everyday work and relate it to my activities.

Shane Hersh

Materials Handler

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

Best course instructor I've ever had. Funny, relatable, engaging; made it interesting and challenged us as the professionals we are.

Amanda Schwartz

Environmental Coordinator

I really enjoy your workshops. Thank you for such a great program and all the help Lion has provided me over the years!

George Chatman

Hazardous Material Pharmacy Technician

Download Our Latest Whitepaper

Knowing why TSDFs reject loads of hazardous waste—and the exact steps to follow if it happens—can reduce your anxiety and uncertainty about rejection.

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.