November 2018

Here’s the latest update on e-Manifest: 

  • Acceptance of the e-Manifest is still crawling along. USEPA reported on 10-31-18 that it has received 496,251 manifests from 6/30 to 10/30 and only 1,310 had been transacted fully – that continues to be less than 1%
  • It appears that the transactions of fully electronic e-Manifests are mostly occurring within the TSDF community, where TSDF’s are shipping to other TSDF’s in their network.
  • USEPA has still not released functionality to companies like WTS that will allow us to electronically prepare manifests for clients. USEPA continues to say that this functionality will be available in 2018.
  • One facet of the program that is now available (effective 11-01-18) is public access to view executed manifests via the RCRAInfo Web. Check with your WTS representative for information on the same.
  • Generators and transporters should be checking in their respective e-Manifest portals to ensure that they can access executed manifest copies to meet record retention requirements.
  • Effective 12-07-18, PHMSA (USDOT) is updating some of its rules including formalizing that electronic signatures are allowed on the e-Manifest to harmonize with HMR.
  • This does not relieve the requirement that if an e-Manifest is utilized, an executed paper copy still must accompany the shipment.