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What You Need to Know about EPA’s New e-Manifest System

Advances in technology are meant to simplify lives and make jobs easier. When it comes to hazardous waste, many business leaders are largely unfamiliar with the industry – which can make it difficult to comply with the ever-changing regulations of generated waste. That’s why the EPA recently established the Hazardous Waste Electronic Manifest Establishment Act, or e-Manifest, a system that tracks hazardous waste shipments electronically in an effort to improve visibility to manifest data and minimize environmental impact.

The e-Manifest system will benefit businesses in many ways, including cost savings, accuracy, more timely information on waste shipments and rapid notification of discrepancies or other problems related to a particular shipment. Plus, the EPA estimates the transition from a paper-intensive process to an electronic system will reduce the burden associated with preparing shipping manifests by between 300,000 and 700,000 hours, saving state and industry leaders more than $75 to $95 million annually.

With this transition comes new logistical challenges, changes in pre-established processes and added regulations. Discover what all business leaders must know about this new system and how they remain compliant.


Understanding the e-Manifest System

To understand the e-Manifest system, one must first know what the new electronic system will replace. For years, businesses have used the Uniform Hazardous Waste Manifest, which is a carbon paper document. Whenever shipping a regulated hazardous waste material in the US, the material must be properly described on a shipping paper. The manifest also includes essential information, such as federal or state waste codes, to help ensure all waste is appropriately tracked, transported and disposed of.

In 2012, Congress enacted e-Manifest. This required the EPA to establish a national electronic manifesting system to reduce waste management costs, as well as improve regulatory oversight and data quality.

This national system modernizes the beginning-to-end hazardous waste tracking process and saves important time, resources and dollars for industry and states. Furthermore, this new electronic system eliminates the need for generators, transporters and treatment, storage and disposal facilities (TSDFs) to provide manifest information to state regulatory agencies, as they will now have access to that information in the national e-Manifest system online.

The EPA launched the e-Manifest system on June 30, 2018. However, the EPA will not phase out paper manifests completely until June 30, 2023.


Benefits of e-Manifest

As mentioned, the e-Manifest system will offer several benefits for generators, transporters and TSDFs, including:

Long-term cost savings;
Accurate and more timely information on waste shipments;
Rapid notification of discrepancies or other problems related to a particular shipment;
Creation of a single hub for one-stop reporting of manifest data for use by EPA and states;
Increased effectiveness of compliance monitoring of waste shipments by regulators; and
The potential for integrating manifest reporting with Resource Conservation and Recovery Act (RCRA) biennial reporting process and other federal and state information systems.

While there are many benefits of this new program for business leaders, states and the environment alike, this program will generate additional fees for organizations.


Costs Associated with the New Program

Most noticeably, the most prevalent change with the e-Manifest system is the costs associated with the program.

In effect until Sept. 30, 2019, the current fee structure will be invoiced to the TSDF on a monthly basis for each manifest submitted to the system dependent on the format of submittal. TSDFs then have 30 days to submit the information to the EPA system after signing off. The EPA will then make the information available to the public within 90 days.

Included below is the final fee schedule for the e-Manifest system, as released by the EPA:

$15 per manifest: Paper copy mailed from TSDF to EPA; EPA enters all data points into e-Manifest system
$10 per manifest: PDF of final manifest uploaded by TSDF to e-Manifest system; EPA enters all data points
$6.50 per manifest: PDF of final manifest plus API file of all manifest data points uploaded to e-Manifest system
$5 per manifest: API file of all manifest data points plus Cross-Media Electronic Reporting Rule (CROMERR)-compliant signature files uploaded to e-Manifest system

Since these fees are an added expense for many organizations, some waste management companies are choosing to bill costs back to their customers for using the EPA database and inputting all data manually. For these reasons, businesses should consider regulated waste management solutions providers who use their own system to avertsupplementary costs.


New Logistical Challenges

Businesses will see the biggest difference with e-Manifest in the various logistical challenges posed by these new regulations, some of which will need to be overcome prior to the industry rollout of a full electronic manifest. These challenges include continuously changing IT requirements, system architecture and timing and TSDF administrative burden.

First, companies with small IT infrastructures may find it difficult to comply with e-Manifest regulations. In turn, they must pay IT consultants to re-format systems, which will lead to an increased cost of rush fees and urgent updates. This single EPA requirement has made it difficult for these smaller companies to comply with this new system as there have been changes to multiple systems, frequent IT adjustments to accommodate program tweaks and everchanging requirements.  

System architecture and timing is another additional challenge for businesses. In the week prior to release, the EPA was still testing system functionality and capacity limits. This ultimately left the system with insufficient time to finalize IT programming, testing uploads and debugging. Moreover, this system was built for generators to create manifests when most manifests are created by industry.

Businesses are also seeing e-Manifest challenges with TSDF administrative burdens. This includes IT system changes, manifest data quality control checks, additional invoicing reconciliation, generator status confirmation and more.

While this new system poses several new challenges and obstacles for businesses to adhere to, one way to ensure compliance is to find an experienced third-party regulated waste management solutions provider. These companies are designed to assist businesses in policy adherence and will provide knowledgeable guidance to ensure its customers remain safe and compliant with all procedures.

It can be difficult for any company to navigate new regulations, which is why it’s so important for businesses to find a top regulated waste management solutions partner to help steer this new system before it’s too late. After all, the risk of not following these regulations can be detrimental. If generators are not compliant or behind the industry standard in regards to data submission to EPA and state agencies, consequences will arise, making it that much more important that companies find a way to properly adhere to this new system.

By Maricha Ellis, vice president of marketing and sales operations for Stericycle Environmental Solutions


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