July 17, 2018
Summary of e-Manifest System Information
Below is a summary of the information that EPA has provided regarding the e-manifest system that took effect in all states on June 30, 2018.
- EPA has held and published monthly webinars since early 2017. These have provided an update on the progress on the development of the system and given the community an opportunity to ask questions on various issues. EPA is planning on continuing to hold monthly webinars even after the June 30 launch, and materials from past webinars are still available.
- To use the e-manifest system, you must have a registered account. EPA has provided a series of brief videos at LearningZen on how to register your account at RCRAInfo so that you may use the e-manifest system. These videos are short and very useful. We also have a previous article detailing the video and account registration process.
- Stakeholder fact sheets are available detailing the impact e-manifest will have on various stakeholders. Stakeholders may include anyone from brokers to generators to inspectors. The fact sheets are written from EPA’s perspective, based on the federal regulations, so make sure to check for your own state-specific information.
- The paper Uniform Hazardous Waste Manifest has been updated. The top two pages of the previous 6-page form (for the shipping and receiving states) have been removed and replaced with a single page labeled “Designated Facility to EPA’s e-Manifest System” that will be sent to the e-manifest system. This results in a 5-page form with the information required in each field remaining the same. Shipping and receiving states will now get their information from the e-manifest system.
- EPA has instructions on how to submit a manifest, whether an electronic copy or paper submittal. If a paper manifest is used and all handlers sign the paper manifest, then the receiving facility must mail the top manifest copy (and continuation sheets) to: EPA e-Manifest PPC, 14295 Park Meadow Dr. 5th Floor, Chantilly, VA 20151.
- A paper copy of an e-manifest can be printed through the e-manifest system. A paper copy is recommended to be printed to assist transporters in complying with DOT regulations and as a backup in the event the e-manifest system goes down.
- User fees have been established based on manifest submission type (see table below). EPA will invoice receiving facilities for each manifest submitted. The receiving facility’s e-manifest site manager will be responsible for receiving and paying the invoices for their particular site(s). Invoice payments will need to be made online through the e-manifest system as no mailed checks will be accepted.
Manifest Submission Type | Fee per Manifest |
|---|---|
Mailed-in paper manifest | $15.00 |
Scanned image upload | $10.00 |
Data + image upload | $6.50 |
Electronic manifest (fully electronic and hybrid1) | $5.00 |
Source: http://www.epa.gov/e-manifest/e-manifest-user-fees-and-payment-information
1A hybrid manifest is a paper manifest that the generator signs (and keeps a paper copy) but that is subsequently converted to an e-manifest by the transporter/TSD facility. [§262.24(c)(1)]
- Manifests that contain P- and U-codes related to the Department of Homeland Security’s chemicals of interest (COI) must be submitted as a paper copy only. This is a last-minute update announced on the e-manifest system listserv and no additional details have been announced as of July 9, 2018. This raises questions regarding the fee structure, where the paper manifest would be mailed to, and how the information would be made available electronically. If you do not manage COI, this may not be a concern to you.
- If you would like to participate in an open forum for discussing news and information related to e-manifest, you can subscribe by sending a blank message to eManifest-subscribe@lists.epa.gov. To contribute to the forum, you may send a message to eManifest@lists.epa.gov.
- EPA published an extensive list of e-manifest frequently asked questions in May. McCoy also summarized some of those questions that are frequently asked in our seminars.
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Considerable care has been exercised in preparing this document; however, McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with the publication of this information. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which this information may conflict. McCoy and Associates, Inc. does not undertake any duty to ensure the continued accuracy of this information.
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.
