On June 30, 2018, the US EPA will officially launch a system that will provide electronic tracking for hazardous waste shipments (“e-Manifest”). This system will streamline cradle-to-grave hazardous waste tracking for generators, transporters and receiving facilities.
Use of the e-Manifest system is optional starting June 30, 2018. TSDs and receiving facilities will be responsible for submitting data to the US EPA for all hazardous waste manifested shipments. Manifests can be submitted through regular mail (paper manifest), by scanning a PDF image to US EPA, by a hybrid of scanning and entering data or by creating and submitting complete electronic e-Manifests in the system.
Heritage-Crystal Clean, LLC (HCC) will continue to use paper manifests after the effective date of June 30thas the DOT still requires paper manifests for the transport of hazardous materials. HCC considers this course of action to be the most stable, safe and compliant. This process is like our current manifest practices and should not require additional actions by our customers or transporters. HCC will transition to a fully electronic e-Manifest when we are confident that our customers and receiving facilities are fully prepared.
- e-Manifest systems will affect everyone including generators, transporters, receiving facilities, US EPA, and state agencies.
- e-Manifest data is required to be submitted by the receiving facility to the US EPA within 30 days of waste receipt. This applies whether the generator uses the e-Manifest system or paper manifests.
- The manifest is the only paperwork that should be submitted to the US EPA (e.g. no LDRs).
- Manifest data will be made available to the public 90 days after receipt to the US EPA.
- Receiving facilities are required to submit the data for state-regulated waste even if the waste is not regulated by the destination state.
- No claims of Confidential Business Information (CBI) are allowed with limited exceptions (e.g. Homeland Security).
A new 5-copy paper manifest will be required under the new e-Manifest requirements. The US EPA is in the process of making the new form available. As of June 30, 2018, HCC will continue to use the current supply of 6-copy paper manifests but is required to eliminate page 1/top copy. The new 5-copy manifest will merge pages 1 and 2 into page 1 for submission to the US EPA (i.e., State copies are no longer required). Within 90 days of receiving manifest data the EPA will provide access to states, registered generators/customers and transporters. To view the manifest data, HCC encourages all parties to register with the US EPA’s e-Manifest system.
This is a link to the US EPA Generators Fact Sheet that will provide information on how to register on the new e-Manifest system:
In order to access e-Manifest here is a link on how to obtain an EPA ID Number on EPA Form 8700-12: https://rcrainfo.epa.gov/rcrainfoprod/action/secured/login
According to the e-Manifest mandate, the receiving facilities will be billed manifest transaction fees by EPA. The fees are based on how the information will be submitted to the e-Manifest system. Currently, estimates range from $4 for each electronic manifest submission to $20 for paper copies. HCC is evaluating the methods being used to determine fees under the new system and will provide additional information on final costs once they are published.