March 14, 2019

Improving Data Collection via the Hazardous Waste Manifest

EPA is seeking public comment on modifying the hazardous waste paper manifest and e-manifest templates. [84 FR 2854] The proposed improvements would serve three main purposes: 1) improve the precision of waste quantities and units of measure reported in Items 11 and 12 of the manifest, 2) enhance the quality of international shipment data reported on the manifest, and 3) assist EPA with integrating e-manifest and biennial reporting requirements. Each of these improvements is explored further below.

Improving the Precision of Waste Quantities and Units of Measure

In the past, some state databases were not designed to receive waste quantity data reported as fractions or decimals. States were also concerned with potential errors in interpreting fractions or decimals that were entered into Item 11 of the manifest. In the March 2005 final hazardous waste manifest rule, EPA responded to these concerns by deciding against allowing the use of fractions or decimals to report waste quantities on the manifest.

In light of the implementation of the e-manifest system, EPA is revisiting this issue. The e-manifest system could be designed to accept fractions or decimals in Item 11 without the concern of misinterpretation of waste quantities or introduction of errors. The e-manifest system could also be configured to accept smaller units of measure, such as ounces, grams, and milliliters in Item 12 of the manifest, resulting in improved precision of waste quantity data.

EPA requests comment on whether or not fractions and decimals should be allowed in Item 11 of paper and e-manifests. If so, what are the potential impacts on state and industry database systems? Additionally, would smaller units of measure be appropriate in reporting waste quantities? If so, what units would offer the greatest precision?

Enhancing the Quality of International Shipment Data

Current import/export regulations require specific information to be entered on manifests, including an import/export consent number. However, the existing manifest template does not have a dedicated field for this information. Instead, EPA currently recommends listing consent numbers in Item 14 of the manifest. Additionally, in situations where an exporter is a separate entity from the site initiating an export shipment, there is no existing field on the manifest to enter the exporter’s EPA ID number. Therefore, the agency is exploring options to allow a separate exporter to clearly identify itself by entering its EPA ID number on the manifest, either in addition to or in lieu of the EPA ID number for the generator site. International hazardous waste shipments also require the use of a separate movement document. While the e-manifest system could be designed to incorporate the required information from the document, there is little room on a paper manifest for this information.

EPA requests comment on its proposal to add a new data element on the manifest for the import/export consent number for each waste stream. The agency also seeks input on how an exporter’s EPA ID and name/address could be entered into Items 1 and 5, respectively, on a manifest or if a separate field should be added to capture this information in the event the exporter is not the generator of the waste. Alternatively, should EPA rely on the waste stream consent numbers from the Waste Import Export Tracking System to record this information instead of adding new data elements on the manifest? Could a manifest’s continuation sheet be used to collect this information as well as all of the information that is required on a movement document?

Integrating Biennial Reporting With the e-Manifest System

The statutory language in the e-Manifest Act requires EPA to build the e-manifest system to provide users with the ability to include hazardous waste data applicable and transferable to the biennial report. This requirement is partially met in the existing manifest by the collection of facility EPA ID number, name, and address; total quantities of waste shipped offsite; and management method codes for hazardous waste treatment, storage, and disposal. But there are three other data elements specifically required on biennial reports that are not currently captured on manifests: 1) source codes describing how the hazardous waste originated, 2) form codes providing information about the physical form or chemical composition of the hazardous waste, and 3) waste density data if hazardous waste quantities are reported using volumetric measure. While the e-manifest system allows users to voluntarily report source codes, form codes, and waste density data, the paper manifest has no such dedicated fields for this information (although such data can be entered in Item 14). EPA believes the addition of these biennial report data elements to the paper manifest is an important step toward full integration of the biennial report with the manifest system.

EPA requests comment on whether or not source codes, form codes, and density information should be required for completion of both paper and e-manifests. Should EPA expand Item 19 of the manifest to include these data or create new data fields? Also, are there other data that should be recorded on the manifest for biennial reporting purposes?

Submitting Comments

If you have suggestions on the agency’s proposals as outline above, the preferred method of submitting comments is via www.regulations.gov and referencing Docket ID Number EPA-HQ-OLEM-2018-0756. Comments must be submitted by April 9, 2019.

 


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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.