E-Manifests Go Live on June 30—Are You Ready?

If you work with hazardous waste, by now you hopefully are aware that the Environmental Protection Agency (EPA) will be using electronic manifests (e-manifests) for hazardous waste shipments moving forward.

The new electronic manifest system will replace the current paper manifests that have been used for years (technically known as the Uniform Hazardous Waste Manifest – EPA Form 8700-22).
If you are not aware, the time to learn is now: EPA will officially unveil the e-manifest system on June 30, 2018. That leaves just 25 days (18 business days!) to prepare for the new system and how it will impact your facility.

Join a full-time Lion instructor and RCRA expert and learn what you need to know to ensure a transition to electronic Manifests at the EPA’s New E-Manifest System Webinar. Be confident you understand the new system, how it will be used, and how it will impact your off-site shipments.

Where Do I Create E-manifests?

To create an e-manifest, you will use an EPA portal called RCRAInfo.  This can be found at https://rcrainfo.epa.gov.

This online portal existed prior to the e-manifest. Generators in states that have opted-in to RCRAInfo used the portal to submit biennial reports and site notification. However, states are now required to use RCRAInfo in regard to creating e-manifests. States will be automatically “opted-in” to the new e-manifest system, whether they want to or not.
 

Can I Still Use Paper Copies of the Manifest?

Initially, anyone who creates manifests (e.g., generators, transporters, TSDFs, brokers, etc.) can continue to use paper manifests. However, preparers will eventually need to switch over.  There are benefits to using e-manifests as opposed to papers copies (e.g., reduced costs, real time tracking, paperwork reduction, etc.), but ultimately, there is also a mandated transition.

If you are a “receiving facility” (e.g., TSDFs), you will be required to use the RCRAInfo portal within 3 years.  If you are a generator, that transition period is 5 years.  The sooner you start using the system, the easier it will be on you down the road.

But Will I Be Able to Use E-manifest in My State?

There is a general feeling for some that, because they live in a particular state that has more stringent rules (California and Texas come to mind), the e-manifest will not be ready for them.  Just to put it simply, your state must be ready for e-manifest.  They do not have a choice.

As such, all of your waste (whether it is Federal or state-specific waste) can be put on an e-manifest.  And this will all happen on the same day – June 30.  There is not transition period of 1 or 2 years for state adoption.  It goes live everywhere on the same date.

The Good News About E-manifests

The good news is that e-manifest is very user friendly and easy to use.  There are many benefits to using it, and in the long run, it will help you. In the beginning, you will have a small learning curve, but once you are over that hump, it will be smooth sailing.

 

Tags: e-manifests, manifests, new rules, RCRA, Recordkeeping and Reporting