E-Manifest Update

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The latest on the US EPA’s e-Manifest Launch …

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As many of you are aware, effective June 30^th of this year, EPA will launch an electronic manifest (e-Manifest) system.  This is a centralized, EPA-operated software platform to record all hazardous waste manifest activity.  Rest assured that Heritage has been diligently participating in the implementation process.  Our primary goal, dictated by our core value of “Safe and Compliant or Not at All,” is to safely and compliantly manage the shipment of your hazardous wastes. 

Heritage will continue to use paper manifests to manage waste shipments.  Paper manifests are the least disruptive and have the lowest impact on the hazardous waste generator community.   We have selected Option 3 from EPA’s acceptable list (see below).  For Option 3, the TSD performs nearly all of the “electronic” parts of the e-Manifest process.  Heritage will continue to work with EPA as they update the e-Manifest system.  Heritage will offer a fully electronic manifest option when it is prudent considering our dedication to our customers, safety, and compliance.

e-Manifest Options

EPA has had a pilot version of the e-Manifest system available to the general public for several months.  Unfortunately, this system is still under active development.  Several key features are currently not available or require enhancements.  Additionally, the timing and content of new system updates is uncertain.

The five Options for manifest submission established by EPA are listed below, from the most economical to the least:

• Option 1: Completely electronic manifest;
• Option 2: Hybrid manifest, which starts on paper and the transporter converts to electronic;
• Option 3: Paper manifest to the TSD, where the TSD submits data and a manifest scanned image after shipment is complete;
• Option 4: Scanned copy of the manifest with minimal data uploaded; or
• Option 5: Paper copy mailed directly to EPA.

Option 2 is currently not available.  Very few details have been released as to how EPA will do electronic conversions for Options 4 and 5.

Signature Issues

Option 1 manifests require CROMERR signatures by all parties.  This type of signature is more than using a conventional tablet to sign your name, and EPA has not approved any CROMERR-compliant hardware to date.  EPA will provide a web-based application that supports electronic signatures.  However, this requires the completion of a registration process for the electronic signers, and full registration features are currently not available.  Additionally, while there will be a mechanism to copy a previous manifest in the EPA’s e-Manifest system, it does not accommodate the electronic waste profile information that Heritage has in our system.  Heritage is working on fully electronic manifesting which will allow our customers to configure manifests online, much like our current ordering capabilities.

Continuing Paper Requirements

The e-Manifest system will still require that some paper be used for every shipment, even for the completely electronic Option 1.  The requirement for paper land disposal restriction forms to accompany at least the first shipment of a new wastestream has not been removed.  DOT requires paper to be available with the truck driver for emergency response purposes.  The transition to a completely paperless shipment mode will require additional regulatory actions from both DOT and EPA.

Finally, a modified paper manifest for e-Manifest was also introduced by EPA.  We will be working with our paper manifest providers to transition to the new form.
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Cost of Implementation

Every hazardous waste manifest, whether paper or electronic, will have a fee.  The fee is assessed to the receiving TSD by EPA.  EPA has established a draft fee schedule for each manifest submission Option, but the final fee schedule is not yet available.  In addition, fees for hardware-based (e.g., tablet) compliant signatures are not known, since EPA has not yet approved any third-party providers.  Heritage will share our fees associated with manifesting as these items are completed.

Path Forward

If you have any questions, comments, or concerns, please share them with your customer service representative or account representative.  We will provide another update in early April.
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