The U.S. Environmental Protection Agency (EPA) is implementing its new nation-wide e-Manifest system beginning June 30, 2018. With the promise of adding significant streamlining to the tracking of hazardous waste shipments, EPA has been working with states for several years to make this a reality.
The use of the e-Manifest system is voluntary for now. Hard-copy manifest forms – available through EPA-approved registered printers – are still an option, at least initially. You may use either:
- – the new 5-part hazardous waste manifest; or
- – the current 6-part hazardous waste manifest – if the forms are revised to reflect the new 5-part manifest.
The new 5-part manifest consists of:
- + Part 1: Designated Facility (to EPA’s e-Manifest System)
- + Part 2: Designated Facility (to Generator)
- + Part 3: Designated Facility Copy
- + Part 4: Transporter’s Copy
- + Part 5: Generator’s Initial Copy
How Will the New System Work?
Preparing an e-Manifest (also available on tablets and smart phones) is an adventure where the online system leads you through a series of drop down menus for shipping names and waste codes as well as red flags that alert you when a necessary data field has not been completed. The process can be done relatively quickly and templates can be created for future shipments of similar waste streams.
Here’s a step-by-step guide for a typical e-Manifest process:
1. Hazardous waste generators, transporters, and destination facilities login (or register if not previously registered) with RCRAInfo online to prepare, review, sign and correct a manifest.
2. If you have an existing EPA ID Number / Site ID*, enter that information when requested. If you are a Maine Small Quantity Generator (SQG) or other company who does not have an EPA ID Number specific to your site, you can request one through RCRAInfo or through Maine DEP.
3. The authorized person preparing the manifest can enter the information into e-Manifest about that particular shipment – just as they would normally (i.e. generator information, transporter information, quantity and types of hazardous and other waste).
4. The shipment will automatically be assigned a tracking number.
5. The initial transporter can then sign the manifest indicating acceptance of the waste on his/her conveyance. Until the U.S. Department of Transportation (USDOT) accepts and revises its rules, a paper copy of the manifest will need to be printed out and accompany the transporter during its trip from the generator to the destination facility.
6. Once the shipment of hazardous waste is received by the destination facility, their facility representative will electronically sign the e-manifest and submit it to EPA within the RCRAInfo system.
7. Generators will be able to log into RCRAInfo to look up the tracking number and confirm the shipment was received.
8. The manifest will also be available to the public for viewing 90 days from the date the shipment was received by the destination facility.
9. If any corrections to the e-Manifest are needed, they can only be done by the parties registered on the e-Manifest.
What about SQGs in Maine?
In the past, the Maine Department of Environmental Protection (Maine DEP) assigned a generic EPA Identification Number (MEX020000000) to all SQGs in Maine to list on their manifest when shipping hazardous waste offsite. In preparation for the e-Manifest, Maine DEP has already assigned unique EPA ID numbers to most SQGs in Maine.
As of June 30, 2018, when a manifest with a generic SQG number is entered into the e-Manifest system, it should automatically get flagged and sent to the Maine DEP or you can contact Maine DEP proactively. The Maine DEP will assign a unique EPA ID Number to the manifest and send that number to the SQG to be used on all future shipments of hazardous waste.
Contact Kevin Jenssen at (207) 299-4877 or Cherrie Plummer (207) 287-7882 at the Maine DEP if a unique EPA Identification Number has not been assigned to your facility.
Options and Associated Estimated Fees
The use of the new e-Manifest system or existing manifest forms can result in the following scenarios and estimated fees, which will be accessed to the destination facility:
– All information is entered directly into the new e-Manifest system (by the generator, transporter, broker or destination facility). No paper manifest forms are used.
- The fee for submitting the e-Manifest electronically into the RCRAInfo system is $4.00
– The new 5-part manifest form (paper) accompanies the waste to the destination facility and either:
- A. Once received, the destination facility signs the manifest and mails Part #1 to EPA’s e-Manifest system and Part #2 to the generator.
- The fee for mailing the paper manifest to the EPA, who will then enter it into the e-Manifest system, is $20.00
- B. the destination facility enters the data themselves or scans the form into the e-Manifest system.
- The fee for entering the paper manifest into the new e-Manifest system is $7.00
- The fee for scanning the paper manifest into the e-Manifest system is $13.00
These fees are intended to cover the cost of the new e-Manifest system.
No fees are anticipated for corrections or rejected manifests at this time.
Currently, no Land Disposal Restrictions (LDRs) will be accepted by the e-Manifest system, so be sure to maintain a copy of each LDR in your files.
Non-hazardous waste shipped with hazardous waste on a hazardous waste manifest will be accepted by the e-Manifest system.
Inventory lists associated with labpacks will not be accepted at this time.
Universal bill of ladings will not be accepted either.
Questions and Training
If you have any questions or are in need of assistance either using EPA’s new e-Manifest system or registering into the RCRAInfo database, contact Mike Rioux, CHMM at St.Germain Collins: 207-591-7000.
Please note that training on the e-Manifest system will also be included at no additional cost in our upcoming Maine-Specific Hazardous & Universal Waste and also U.S. DOT Shipping Hazardous Materials training sessions.