February 15, 2021

Documents Available in Preparation for March 2021 e-Manifest Meeting

On March 2–4, 2021, EPA will hold a virtual three-day public meeting with the e-manifest advisory board to seek the board’s consultation and recommendations on the e-manifest system. Those wishing to attend or provide comment must register via the e-manifest advisory board website. The agency has provided information on the meeting’s theme “Looking Ahead: Setting e-Manifest Program Priorities and User Fees for FY2022 and FY2023” via Docket No. EPA-HQ-OLEM-2020-0571. Included is an e-manifest white paper, a set of specific questions the agency is seeking to answer, and an e-manifest fee worksheet including proposed FY2022–23 fees.

The e-manifest white paper breaks down the history of the e-manifest system and highlights future objectives. Since FY2020, reports and bulk manifest data extracts have been made public, states can correct manifest data or flag them for review, and industry users can bulk sign manifests, download site reports, and create warnings for certain discrepancies. There is a host of additional functionality planned for the near future as well. RCRAInfo updates are expected to provide a more efficient download of public manifest data, states will see improvements to their reporting database, and industry users will see broker enhancements, optical character recognition, and a new billing-only role.

Other future efforts will focus on increasing e-manifest system usage, biennial report integration, and a third rulemaking to add exports and supplementary reports to the e-manifest system. One priority for the regulated community, particularly designated TSD facilities, is to move away from mailing paper manifests to the e-manifest system. EPA will no longer accept mailed manifests for processing after June 30, 2021. After that date, the only submittals that will be accepted are image uploads, image plus data uploads, and fully electronic manifests.

Proposed FY2022–23 fees

The equations used to calculate e-manifest fees are found in Subpart FF of Parts 264 and 265. Based on those equations, the e-manifest white paper includes proposed e-manifest fees for FY2022–23, as noted in the table below.

e-Manifest type

FY 2020–21 fees1

Proposed FY 2022–23 fees1

Paper

$25.00

2

Image upload

$20.00

$20.00

Image + data upload

$14.00

$13.00

Fully electronic

$8.00

$8.00

1Fees are effective from October 1 of the preceding odd-numbered year through September 30 of the next odd-numbered year.

2EPA will not accept mailed manifests after June 30, 2021.

Source: McCoy and Associates, Inc.; adapted from Hazardous Waste e-Manifest Advisory Board March 2021 Meeting Background White Paper, available at Docket No. EPA-HQ-OLEM-2020-0571.

 


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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.