hazardous waste e-manifest

Hazardous waste generators get invoiced for an “EPA Electronic Manifest Program Fee.” Why? What is this fee used for? Let’s see if we can answer that for you.

The EPA regulates all types of hazardous waste (HW) generated in healthcare, from spent solvent (such as alcohols and ketones) and pharmaceuticals to diagnostic testing procedure residuals. Much of the HW that these businesses generate must be shipped long distances to treatment, storage, and disposal facilities (TSDFs) where it can be properly disposed of or recycled.

Hazardous waste must be tracked throughout its entire life cycle (cradle-to-grave) so that the EPA and other regulatory authorities can determine its origin and destination and know it was properly managed. Following waste from start to finish reduces the risk of fines from improper dumping and harmful environmental consequences.

What Is the EPA e-Manifest?

On June 30, 2018, the EPA launched a national system for tracking hazardous waste shipments electronically. This system, known as the “e-Manifest system,” modernizes the nation’s cradle-to-grave hazardous waste tracking process while saving valuable time, resources, and dollars for industry and states.

The EPA established e-Manifest per the Hazardous Waste Electronic Manifest Establishment Act, which Congress enacted into law on October 5, 2012. e-Manifest is a multi-faceted program that includes the following:

  • System development
  • Regulation and policy
  • Implementation and communication
  • Consultation with the e-Manifest federal advisory committee

The e-Manifest system offers generators, transporters, and receiving facilities a digital one-stop shop for manifest tracking and recordkeeping to meet their regulatory requirements. Receiving facilities upload manifest copies at the end of their lifecycle, and generators can log in to view their completed manifest copies.

Hazardous Waste Paper Manifests

The EPA set June 30, 2021 as the deadline to ensure all TSDFs report manifest information to RCRAInfo (the program which hosts e-Manifests) electronically. Now, the EPA will no longer accept paper manifest submissions from TSDFs, but paper manifests may still be used from the HW generator location for shipments to the TSDF.

Paper manifests are still used for over-the-road shipments because the larger HW service providers have not yet aligned their software tracking systems to the EPA’s digital architecture. It is all still a work in progress, funded by the e-Manifest program fees.

Improving the e-Manifest System

The EPA is committed to ensuring that the e-Manifest system must meet its users’ needs. To accomplish this goal, they are:

  • Conducting user-centered design
  • Developing and utilizing agile software development methodologies

This approach enables continuous improvement through pilots and testing, using iterative processes, and regular engagement with users and stakeholders throughout the process. The EPA will continue to provide ongoing opportunities for input until a full-scale system is complete and thoroughly tested by all entities.

e-Manifest Fees: Who’s Paying for This Program?

The development of this program is costly to the EPA, so money is collected to defray these costs. The EPA publishes user fees by July 1 of each odd-numbered calendar year on their website. These published user fees will then cover the two fiscal years beginning on October 1 and ending on September 30 of the next odd-numbered calendar year. These fees are updated to reflect actual program costs and manifest usage.

The user fee is charged to receiving waste facilities (TSDFs) for each manifest they submit to the EPA. Generators, transporters, and brokers are not directly charged. Thus, the TSDF will pass along this cost from the EPA to their customers who deliver the waste for management.

If you have questions about the e-Manifest program and the fee structure, call Sharps Compliance at 800.772.5657 to learn more.

Joe Jordan has a Bachelors of Arts degree in Chemistry from Washington and Jefferson College. He is certified in RCRA and DOT as well as 40 Hour HAZWOPER certified. Joe has been in the hazardous waste industry since 1990 and has managed industrial, healthcare, retail, and governmental clients, both large and small.

published in Hazardous Waste