It’s here! The long ballyhooed e-Manifest program goes live tomorrow – June 30. Here’s a synopsis of what you need to know as of now:
- The transition to a fully electronic manifest system will be gradual. WTS expects that it will be months or even longer till everyone is on board. USEPA will allow for this transition to take place over time as industry users adapt to the requirements of the rule.
- Meanwhile, paper manifests will continue to be utilized. All TSDF’s will continue to accept the paper manifest. TSDF’s will no longer distribute executed manifest copies back to the states and a new 5 page form will replace the 6 page form. Page 1 of the executed manifest will now be submitted to USEPA by the TSDF’s. The 5 page form has only recently been approved and is just starting to become available from authorized manifest printers. USEPA is allowing for the use of the 6 page form for an undetermined period of time during this transition period. USEPA is encouraging that preprinted adhesive labels be applied to the Page 1 with updated language as follows: ”Designated Facility to EPA’s e-Manifest System”. WTS is following this guidance and all Hazardous Waste manifests supplied to you for post June 30 shipments should have the label already applied.
- Your state may still require that you submit the generator copy of the manifest to them after shipment. Check with your state regulating authority.
- USEPA recently decided to grant extra time for receiving facilities to submit paper manifests during the initial months after system launch. Under EPA’s regulations, receiving facilities must submit paper manifests to EPA within 30 days of receipt. However, EPA will allow receiving facilities to submit paper manifests they receive between June 30, 2018, and September 1, 2018, by September 30, 2018. This effectively provides receiving facilities up to 60 additional days.
- TSDF’s will have options on how they will submit executed manifest copies to the USEPA and back to the generator. WTS is monitoring this by the individual TSDF. Check with your WTS Technical Representative to ensure that you will be getting your copy for your records. Generators will still be required to maintain a copy of the fully executed manifest for 3 years.
- USEPA has recently finalized the fee structure for June 30, 2018 to September 30, 2019 at which time they will be subject to review. Fees are based on and assessed on the manner of submission of the manifest data from the TSDF’s to USEPA and will vary by TSDF. Follows the current fee structure:
- Mailed in Paper Manifest from TSDF to USEPA $15.00
- Scanned Image Only Upload $10.00
- Data + Scanned Image $6.50
- Fully Electronic Submission $5.00
- It appears that many of the TSDF’s will add a surcharge to the established fees. WTS will continue to monitor this situation and advise our clients of the details as they become available. You should expect to see a new line item charge on your WTS invoices for all Hazardous Waste Manifested shipments dated 6/30/18 and beyond.
- WTS is strongly encouraging all Hazardous Waste manifest users to register into USEPA e-Manifest via EPA’s RCRA Info system. The system allows users to register for several permission levels:
- Site Manager: If you are already registered as a Site Manager in RCRA info, you will have automatic access to e-Manifest when it launches in June. You are encouraged to have at least 2 Site Managers per location (by EPA ID Number).
- Site Managers: Can view, can enter data (create), can edit, can sign electronically, can correct electronically and submit manifests electronically and can approve users and grant permissions (i.e. Viewer, Preparer, Certifier, and Site Manager) to other company contacts at a site.
- Viewer: Can only view, can’t prepare, sign or edit/change the document.
- Preparer: Can view, can enter data (create), can edit but can’t sign.
- Certifier: Can view, can enter data (create), can edit, can sign electronically, can correct electronically and submit manifests electronically.
- All levels of registration should be currently available. Though it is not expected that generators will be creating manifests in the e-Manifest portal any time soon, registration will allow you to access executed manifests that the TSDF’s have submitted to USEPA. Please refer to our March 2018 update for instructions on how to register. You may also find all of our prior e-Manifest updates by clicking Here.