May 19, 2022

Proposed Rule Would Amend e-Manifest Regulations

EPA proposed several changes to the e-manifest regulations on April 1, 2022 [87 FR 19290]. The proposed amendments include:

Adding export manifests to the e-manifest system;
Harmonizing the e-manifest data requirements with those for international movement documents and tracking systems;
Revising the manifest form to improve compliance with import and export consents;
Requiring the generator’s email address on the manifest to accommodate automatic distribution of signed manifests to generators by the e-manifest system, thereby relieving receiving facilities of this responsibility;
Revising procedures for exception, discrepancy, and unmanifested waste reports;
Harmonizing TSCA manifest and RCRA manifest requirements for PCB wastes, including tracking of PCB wastes;
Adjusting the e-manifest fee calculations to support these changes; and
Making a few technical corrections.

The agency also requested comment on a conceptual approach for integrating the biennial report and the e-manifest. Additional information can be found in EPA’s April e-Manifest Bulletin. The agency will be accepting comments on the proposed rule through May 31, 2022. Comments can be submitted via Docket ID No. EPA-HQ-OLEM-2021-0609.

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This document addresses issues of a general nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.