Changes are on the horizon for the hazardous waste manifest system as of EPA’s August 6, 2014, effective rule date. BLR’s recent webinar presentation, Hazardous Waste Manifest System Modification: What You Need to Know, offered an overview on what is in store for generators of hazardous waste, transporters, and owners and operators of hazardous waste destination facilities concerning a new electronic manifest system.

The new electronic manifest rule is expected to reduce manpower burden, costs, and make manifest data more readily available to the Agency, state environmental agencies, and the public. When the rule is implemented, generators will be given the option to change to the electronic system or to stay the course with the paper manifests. The choice must be consistent in all aspects in the manifest process. In other words, if the e-Manifest system is chosen, the generator, transporter, and destination facility must all abide by the same method. This is the same if the paper system is chosen.

The rule will include a service fee to generators who choose to remain on the paper manifest system. In contrast, there would be a fee incentive to use the electronic system. Some other benefits of changing to the electronic system will include instantaneous and readily available electronic confirmations of transportation and delivery available to authorized members, enhanced recordkeeping, easy-to-use dropdown menus and populated forms, electronic devices in place of a typical six-page paper manifest, and thorough cradle-to-grave tracking.

The Hazardous Waste Electronic Manifest Establishment Act was signed in October 2012 and requires that the e-Manifest system be live by October 5, 2015. A system advisory board must also be established no later than 3 years after the bill enactment. The board will consist of nine members, including two IT professionals and three state representatives.

Some aspects of the new e-Manifest rule are still in development. Concerns addressed in the webinar were in regards to information lost, acts of terrorism, media usage, and availability of the location of manifest data to the general public.