January 17, 2019

New e-Manifest FAQs and Data Now Available

A fourth round of e-manifest Frequently Asked Questions has been made available. The latest set of questions primarily deals with discrepancy reporting and rejected wastes. A discrepancy includes a significant difference between the type or quantity of hazardous waste shipped versus what was received, a waste rejection, or a container residue that exceeds the quantity limits for RCRA-empty containers. [§§264/265.72(a)] The e-manifest system does not currently have the functionality to generate discrepancy reports. This means that a receiving facility would have to file a hard-copy discrepancy report, if necessary, to their EPA region or state. The e-manifest system allows users to correct a manifest but not submit the corresponding discrepancy report.

Additionally, the first batch of e-manifest data has been made publicly available via EPA’s RCRAInfo Public Extract site. The data can be accessed by downloading the 108 mb EM.zip file. The extracted information is contained in a huge (over 20 GB) TXT file that will likely require special software to process the large volume of content. The publicly available data is scheduled to be updated every Monday.

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Disclaimer

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.