Hazardous Waste Manifest System Modification What You Need to Know Ahead of August 6, 2014
Jul 08, 2015
Hazardous Waste Manifest System ModificationWhat You Need to Know Ahead of August 6, 2014
Agenda Overview of the e-Manifest rule
Benefits & Impact
Key Dates
Determination of Rollout & Tracking EPA’s Progress
Fees and Manifest-Related Services
Implementation at State Level
Compliance Strategies &Resources
Overview of the e-Manifest rule
Overview
e-Manifest: national electronic manifest system
and user service fees to fund the development
Upgrade current paper-based system
Authorizes e-Manifests under RCRA
Emergency responder access
Overview
e-Manifests = legal equivalent of paper system
Manifest forms are used to track shipments of haz
waste from a generator to disposal
New tools to reduce the reporting burden
Overview
More steps needed to fully implement e-Manifest
Establish the system and initial fee structure
EPA will work with states, industry, stakeholders
Requirements of e-Manifest
“to the same extent as paper manifests under
applicable Federal and State law…”
Track and maintain legal accountability of…
State authority to access paper copies
Access to all publicly available info
Can I still use paper??
Solid Waste Disposal Act
42 U.S.C. 6901 amended by inserting at the end
of the TOC for Subtitle C:
Benefits & Impact
Impact to State Agencies
EPA wants to streamline with state requirements
that currently require paper manifests
Get involved
Talk to State IT staff
Check e-Manifest website often
Ease of Access
EPA initiative to provide the agency, states and
public with easier access to environmental data.
Electronic reporting = enforcement
Reduce burden on preparing written manifests
Impact to RCRAInfo
e-Manifest will be separate from RCRAInfo
Impact on other shipment
tracking systems
“In Transit,” “Delivered” after manifest is signed
Differences:
Applies to entire shipment
Tracks additional information
40 CFR coordination
EPA still evaluating technical implementation of real-
time tracking of shipments.
Inclusion of all manifests
Paper and e-Manifest data
Transition from paper to e-Manifests
Fee structure
Other benefits
Drop-down menus and pre-populated forms
Track shipments and receive delivery and
acceptance confirmations
Recordkeeping
Mobile devices carried on transport vehicles
Cradle to Grave tracking
Eliminate 6 page paper manifest
Impact on other Regs
Electronic reporting for other permits -
Stormwater, NPDES
Permit records and compliance history accessible by the public
Stakeholders concerned about accuracy of
data and data being misinterpreted or
misconstrued
Stormwater permit initiative = $60M budget request for 2014.
Key Dates
One Year Rule
Oct 2012: Haz Waste e-Manifest Establishment
Act
October 5, 2013:
Authorizes e-Manifests.
System and fee structure must still be established by
EPA to implement the e-Manifest.
The NEXT rule will establish the initial fee structure
and announce the actual implementation and
compliance date for their use.
Publicly available data…
System Online
e-Manifest system to be online by October 2015
Shipments cannot be electronically tracked until
then
Funding has not been received yet
Determination of Rollout & Tracking
EPA’s Progress
When will it be online?
3 years from the signing of the Act
Signed October 2012
Online by October 2015
Advisory Board
No later than 3 years after enactment of bill
9 members
Chairperson
8 appointees by Administrator
2 = IT
3 = users
3 = State rep
Timeline
Rule was finalized in early 2014
Next rule to establish fees
October 2015 deadline
Technical details: system design, operation,
security, fee structure
Final Rule Electronic signature legal and enforceable
Manifest info – available after 90 days after considered “complete and final”
Opt-out options
Paper and electric
DOT shipping paper requirements
Record retention requirements
Electronic signature
Authorization
Fees and Manifest-Related Services
How will the fees be set?
EPA to set initial fees via rulemaking in
consultation with IT vendor(s).
2014
Operation, maintenance, and development of
system
Establish board by October 2015
Fees
Stakeholder communication and participation
Will e-Manifest system conflict or add work to
current DOT requirements.
It is still necessary to carry a printed manifest on
transport vehicle during transport of haz waste
subject to haz mat regs
Implementation at State Level
Non-RCRA wastes requiring
manifests under state law
Fed RCRA haz wastes
State-regulated wastes that require manifest by
state law
States will not be permitted to require different or
additional e-Manifests
State Compliance
Complete the facility portion of the applicable
manifest
Sign and date the facility certification
Submit to the system a final copy of the manifest
data for processing purposes
Compliance Strategies &Resources
Get Ready for e-Manifest
Get Involved
Talk to your generators, transporters, TSDFs, IT staff
Check the e-Manifest website often
Subscribe to the e-Manifest ListServ
Generator
Benefits:
Fill out manifests online
Track shipments and receive confirmation
Recordkeeping
Communicate and participate with EPA
Communicate with transporters and TSDFs
Transporter
Benefits
e-Manifest on mobile devices
Cradle to Grave racking
Eliminate current 6 page paper manifest
Minimal need for DOT-required paper manifests
TSDF
TSDF = key customer of e-Manifest system
Communicate and participate with EPA
Communicate with generators and transporters
Haz Waste Shipments by Rail
Electronic waybill system to track location/status
e-Manifest is primarily for highway shipments
EPA will coordinate with rail industry
Concept of Operations
EPA will host outreach and communications
webinars and meetings in 2014 with stakeholders
to discuss technical design
Online Resources
Text of the bill (21 large text pages)
http://www.gpo.gov/fdsys/pkg/BILLS-
112s710is/pdf/BILLS-112s710is.pdf
EPA Landing Page for e-Manifest
http://www.epa.gov/waste/hazard/transportatio
n/manifest/e-man.htm
Con-Ops doc
http://www.epa.gov/waste/hazard/transportatio
n/manifest/pdf/eman_conops.pdf
EPA Points of Contact
Per Con-Ops Doc
e-Manifest ListServ
Subscribe by sending blank message to
Contribute by sending message to [email protected]
Unsubscribe [email protected]
Thank you!
Continue the conversation –
Abby Ferri, CSP
612-567-9981
@abbyferri
Abby Ferri, CSP
+AbbyFerriCSP