November 16, 2020

EPA to Reduce Burden for Signing e-Manifests

One of the impediments to the use of e-manifests is the requirement for all generators, transporters, and receiving facilities that electronically sign manifests to register their e-signatures in full compliance with Cross-Media Electronic Reporting Rule (CROMERR) requirements under 40 CFR Part 3. In a meeting held April 14–16, 2020, the e-Manifest Advisory Board made several recommendations to EPA for streamlining the e-signature registration process, especially for generators and transporters, and increasing the use of fully electronic manifests. The details of this meeting and subsequent board recommendations were discussed in a previous article.

EPA responded to the board’s recommendations in a document posted to on October 19, 2020. After considering the board’s input, the agency decided to eliminate the requirement for generators and transporters to meet CROMERR requirements for their e-signatures. This will allow these entities to sign e-manifests with a mouse click and forgo the 3-step CROMERR electronic signature process (see comparison chart below). Designated TSD facilities and entities wishing to make corrections to an e-manifest will still need to have CROMERR-compliant signatures.

Existing CROMERR process

Future revised process

User registration steps

Create account

Request access to site as a Certifier or Site Manager

Perform identity validation

Create challenge questions for signature

Create account

Request access to site as a Preparer

User signature steps

Click “Sign”

Re-enter system password

Answer challenge question

Click “Sign” again

Click “Quick Sign”

Source: Adapted from “EPA Response to Recommendations from the April 14–16, 2020 e-Manifest Advisory Board Meeting.”

Besides removing the requirement for generators and transporters to have CROMERR-compliant signatures, EPA is evaluating other ways to encourage the use of e-manifests. The agency is developing another e-manifest rule, which may address 1) issues related to the need for TSD facilities to mail final manifest copies back to generators, and 2) integrating the e-manifest system with biennial reporting requirements. While the e-manifest system already allows users the option of adding biennial report codes, this option is not commonly used. EPA is investigating adding the biennial report form code to the manifest as well as providing tools to auto-populate the biennial report form (EPA Form 8700-13 A/B) with e-manifest data.


©2020-2023 McCoy and Associates, Inc. All rights reserved.

McCoy and Associates has provided in-depth information to assist environmental professionals with complex compliance issues since 1982. Our seminars and publications are widely trusted by environmental professionals for their consistent quality, clarity, and comprehensiveness.



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.