Will you be ready to sign electronic hazardous waste manifests by June 30?
As EPA’s June 30th launch date for the electronic manifest system (e-Manifest) gets closer, many transporters have questions about their role in the system and what the changes mean for them.
The hazardous waste manifest system relies on signatures from generators, initial transporters and any subsequent transporters, and the destination facility for accountability. Transporters have always had to sign the initial copy that is returned to the generator and keep a signed copy for their records. But electronic manifests will make signing a manifest a bit more complicated. To start, drivers must have access to a mobile device, such as a cell phone or tablet.
Here is what you need to know to be ready to sign electronic, hybrid (a combination of paper and electronic), and paper manifests going forward:
- Drivers must register. Each driver who must sign manifests electronically must be registered on EPA’s e-Manifest. E-Manifest is an application in EPA’s RCRAInfo database and uses CDX for its registration. Drivers can register directly with RCRAInfo at rcrainfo.epa.gov/rcrainfoprod. Drivers will need to know the transport company’s EPA Identification Number to register. Drivers will also need to create (and remember) a password. This password will expire every 90 days. There is no charge for registering with e-Manifest.
- Signing paper-only manifests. The driver will sign the paper copy and return a copy to the generator.
- Signing hybrid manifests. The driver will initiate an electronic manifest using e-Manifest and print a copy for the generator for the generator to sign. The transporter will sign this paper copy and return it to the generator. From that point, the remaining manifest completion and tracking will be electronic, either on the transporter’s smart phone, tablet, or other device.
- Signing electronic-only manifests. The transporter will sign the electronic copy and the remaining manifest completion and tracking will be electronic.
- DOT and electronic signatures. The Department of Transportation will not accept electronic signatures at this point. This means that the generators using electronic manifests must print out a copy of the manifest, or the transporter’s page, for the driver to carry in hard copy.
A hazardous waste manifest is a type of shipping paper that must accompany hazardous waste from the time it leaves the generator’s facility until it is accepted at the designated disposal facility. Transporters must be able to show appropriate signed copies of the manifest to enforcement officers and keep a copy of the manifest in their records for at least three years.
On June 30th, the 6-ply paper manifest form transitions to a 5-ply form. This is because two copies that were earmarked for distribution to states will now be replaced with one copy to be submitted to federal EPA for data processing. Instructions on the back of each copy are provided for generators, transporters, and destination facilities. Each copy must be distributed as follows:
- Page 1: Designated facility to EPA’s e-Manifest system
- Page 2: Designated facility to generator
- Page 3: Designated facility copy
- Page 4: Transporter copy
- Page 5: Generator’s initial copy
EPA’s transition from paper-only to electronic manifests is a massive project, and as with any such undertaking there are going to be problems along the way. But transporters can make their own transitions to e-Manifest a little smoother if they know what to expect and start preparing now.