August 14, 2018

Update on e-Manifest System

Below is a summary of the latest information EPA has provided regarding the e-manifest system that took effect in all states on June 30, 2018.

EPA’s latest webinar was on July 24 and provided a formal and structured demonstration of e-manifest capabilities and a Q&A session. Unfortunately, at the time of this article, the July 24 webinar materials are not available on EPA’s website, so you may have to check back a few times to get them. Materials from previous monthly webinars, however, are available.
EPA updated their (extensive) list of e-manifest frequently asked questions in July. One significant change is EPA allowing 60 extra days for a receiving facility to submit a paper manifest copy to the e-manifest system until September 1, 2018. The agency notes, “Beginning on September 1, 2018, receiving facilities must submit all paper manifests to EPA within 30 days of receipt by the receiving facility, as required by the regulations.” In addition, McCoy has a summary of various e-manifest questions that are asked frequently in our seminars.
EPA has set up an e-manifest help desk for both industry and state users.

Industry users: 8:00 am–6:00 pm EST, (833) 501-6826 or (970) 494-5508, helpdesk@epacdx.net.
State users: emanifest@epa.gov or locate EPA regional contacts.

To use e-manifest, you must have a registered account. The videos EPA provided via LearningZen can assist you with registering for e-manifest system access at RCRAInfo. These videos include: creating a RCRAInfo Industry Application (RIA) account, what to do if you already have a CDX account, logging in to RIA, adding sites to your account, requesting a site EPA ID if one is not already available, changing account permissions for various sites you have access to, and establishing an electronic signature. We also have a previous article detailing the video and account registration process.
Since the paper Uniform Hazardous Waste Manifest has been updated to a new 5-page format, the old 6-page format has become obsolete. New manifests from approved registered printers will need to be used unless a manifest is generated via 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 can mail the top manifest copy (and continuation sheets) to: EPA e-Manifest PPC/14295 Park Meadow Dr. 5^th Floor/Chantilly, VA 20151
A paper copy of an e-manifest can be printed through the e-manifest system. To do this, select the manifest, from your list of manifests, with the “eyeball” icon. Once the manifest is selected, there will be a “printer” icon in the upper right hand corner. Clicking on the icon opens a PDF formatted manifest that you may save or print.
Now that user fees have been established based on manifest submission type, the lowest fee of $5.00 will apply for both fully electronic and hybrid manifests. In a fully electronic submittal, all manifest signatories must have access to the e-manifest system. This means the generator (even a very small quantity generator) would need to have an EPA ID and sign electronically. A hybrid manifest, on the other hand, could be used if the generator has not registered for the e-manifest system and thus could only sign a paper manifest. An e-manifest would be created but a paper copy would be printed and signed by the generator and initial transporter and would then remain with the generator. The initial transporter and subsequent waste handlers would all sign the e-manifest with their electronic signatures, and the e-manifest would be submitted to the e-manifest system electronically.
Stakeholder fact sheets are available detailing the impact the e-manifest will have on various stakeholders. Note that these fact sheets are written from EPA’s perspective concerning the federal regulations. Your state may have additional information or requirements as well.

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

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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 environmental regulations. Persons evaluating specific circumstances dealing with the environmental 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.