October 14, 2019

Advisory Board Recommendations on Improving e-Manifest System Adoption

Since going live in June 2018, the e-manifest system is underutilized due to a variety of reasons. Generators, transporters, and hazardous waste receiving facilities face challenges such as lacking “offline” access, unrealized benefits vs. the burden of adoption, integrating existing industry manifesting software with EPA’s system, and much more. Additionally, there is a backlog of hundreds of thousands of paper manifests still waiting to be entered into the system. These challenges make the end-users reluctant to fully utilize the system. Instead, many opt to continue using paper manifests.

On June 18–20, 2019, EPA held a public meeting of the e-Manifest Advisory Board to discuss increasing the adoption of the e-manifest system. The meeting minutes are available and provide insight into possible solutions. The minutes are divided into sections, each addressing the concerns and possible solutions for generators, transporters, and receiving facilities. Some of the possible solutions include establishing a customer service hotline, modifying the user registration process, and the use of biometric signatures. The advisory board indicated that full system functionality may be achieved sometime in 2020 for viewing manifests and perhaps 2022 for biennial reporting purposes. The board also encouraged EPA to “relaunch” the system with a new marketing drive once the paper backlog is addressed and increased functionality is developed.

If you have not already signed up for the e-manifest system, you may register your account at RCRAInfo. Users already having a Central Data Exchange account can use that account information to obtain access to RCRAInfo. Training videos on how to set up your account can be accessed via LearningZen.

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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.