As we enter the month of June, e-Manifest implementation is now less than a month away! Here’s the latest information we can share as of this date:
- WTS has been in discussion with all of our valued suppliers and it is apparent that all TSDF’s will continue to accept PAPER manifests like you are accustomed to after 6/30 and for the foreseeable future.
- This is due to the industry’s recognition that the full-scale EPA e-Manifest production system is not yet available from EPA as of this posting.
- Issues, amongst others include full scale registration into e-Manifest not yet being available and the IT capability of EPA’s e-Manifest system to accept manifests prepared outside of the e-Manifest portal.
- EPA is on record as stating that full functionality should be available sometime after 6/30.
As a result of all this:
- WTS clients can expect to receive their PAPER manifests in the same fashion they currently do. (Remember – the e-Manifest program is strictly for Hazardous Waste Manifests and has no bearing on Bills of Lading, LDR’s, ERG guides, Marks and Labels, etc. that WTS may be currently supplying to you.)
- Generators should continue to use the same process they currently do after signing the manifest and after the transporter signs – keep their copy and send the remaining copies with the load.
- Individual states may still require that generators submit a copy of the generator copy manifest. Check with your state or with your WTS Technical Representative.
- The TSDF’s will accept and execute the paper manifests. TSDF’s will then be responsible for submitting the executed copies to the EPA. TSDF’s will no longer be required to distribute executed copies to either their state or the generators state. TSDF’s can then submit executed copies to the EPA in a variety of fashions including mail or data uploads.
- As mentioned in previous WTS e-Manifest updates, EPA will be assessing a fee based on the type of submission beginning on 6/30 and the fee will in turn be charged to the generators. EPA has still not yet finalized the final fee structure. Refer to our January 2018 update for further information on the fees.
- Based on the individual TSDF’s protocol, generators will receive their copy of the executed manifest via the e-Manifest portal or regular mail as they do today. WTS is monitoring each TSDF’s protocol and will advise and assist our clients in ensuring that they receive their required executed copy for record retention.
- EPA is instituting a new 5 page Hazardous Waste Manifest form to replace the current 6 page form. The 5 page form recently received clearance from the OMB but it is not yet clear if commercial printing houses will have the 5 page form available for use by 6/30. EPA is allowing the use of the 6 page form during the transition period. Rest assured that WTS will be supplying you with compliant documents.
WTS is still strongly encouraging that all generators ensure that they are registered in RCRA Info (https://rcrainfo.epa.gov/) as outlined in our March 2018 update. For clarification on registering sites in States that have not opted into RCRA info for reporting, etc., you may request a Site Manager in any State, by visiting https://rcrainfo.epa.gov/rcrainfoprod/ and registering as an industry user.