July 2019

Here’s the latest update on e-Manifest:

  • Adoption / usage of the fully electronic hazardous waste manifest continues to lag. USEPA convened a meeting last month to specifically address issues around ”Increasing Adoption of the e-Manifest system”
  • WTS was an active participant at the meeting and Larry Fura, of WTS, presented public comments for the record – one of only three industry representatives to do so. Issues identified include:
    • Adherence to the CROMER requirement for electronic signatures.
    • Full registration by Generators and Transporters
    • Transporters having access to electronic devices in order to participate in e-Manifest
    • e-Manifest functionality being available for all participants in the supply chain
    • Lack of regulatory driver that requires use of fully electronic manifests
    • Points raised during the meeting will be undergoing evaluation by USEPA with recommendations/courses of action expected later this year.
  • The regulated community has been informed by USEPA that they should expect a new fee structure. The new fee structure was expected July 1 but it has not been announced as of yet.
  • Of interest is that the program was touted as being self-sufficient – meaning that it would pay for itself.
  • However, USEPA in April 2019 released data that showed it had originally projected collecting 3.5 million manifests a year and was actually on a pace to collect 2 million a year.
  • This will lead to a revenue shortfall that will most likely result in a substantial increase in user fees. We are expecting that the fee for all paper transactions – currently $20.00 per manifest – will undergo the largest increase.
  • WTS will advise our stakeholders of the new fee structure as soon as it is made public.
  • It appears that the TSDF community is still distributing executed manifest copies to generators as they have been all along – via USPS, e-mail, etc. as well as posting in the e-Manifest portal. The regulations for paper manifest submissions specify that a completed manifest must be submitted to the EPA’s e-Manifest system within 30 days of the delivery of the waste to the receiving facility by the TSDF. This 30-day timeframe extends to submission of paper manifests by mail, scanned image, or data upload plus image. Generators need to ensure that they continue to have an executed manifest copy in some fashion for their records.