Subject: U.S. EPA Hazardous Waste e-Manifest System
Effective Date: June 30, 2018
The following information pertains only to Hazardous Waste Manifests.
By now most of you understand that effective June 30, 2018, the U.S. EPA’s e-Manifest System takes effect regarding the Hazardous Waste Manifest. Below please find a brief explanation of the changes regarding this new e-Manifest system.
The United States Environmental Protection Agency (EPA) will launch the Hazardous Waste Electronic Manifest System, better known as the e-Manifest. This is a centralized and digital platform, designed to modernize the nation’s cradle-to-grave hazardous waste tracking process.
The EPA’s intended purpose of this new e-Manifest system is to create a single hub for the reporting of manifest data while increasing the effectiveness of compliance monitoring for hazardous waste shipments. This system should provide accurate and timelier information on shipments, as well as rapid notification of discrepancies or any other problems related to a particular shipment.
The EPA has provided a list of five acceptable options for using the new e-Manifest system. In order to promote continuity, most of the Treatment Disposal & Storage Facilities (TSDF) have selected Option 3 which is explained below:
- Option 3: A paper manifest is still generated and sent to the TSDF. Then the TSDF submits data and a manifest scanned image is sent to the EPA after the shipment is complete.
The Hazardous Waste Electronic Manifest Establishment Act, which governs this process, does not itself set e-Manifest user fees, but instead gives EPA discretion to establish user fees, through regulation, that the Administrator determines to be necessary to offset the costs of developing and operating the e-Manifest system.
What this means to Pinnacle Customers:
Beginning June 30th, each of our approved TSDF locations will upload the required information and image into the EPA’s system and assess fees per each hazardous waste manifest based on the EPA Fee schedule.
The Pinnacle Team wants to be transparent about these TSDF fees:
In order to provide continued unequaled service excellence and a streamlined process, we will continue using paper manifests for your hazardous waste shipments.
The Pinnacle Team goal is to eventually convert 100% of our hazardous waste shipments to fully electronic versions, eliminating the multi-copy form. Unfortunately, the EPA has not completed all of the programming and defined the requirements necessary to achieve our goal at this time. Therefore, we must continue using paper manifests in order to maintain consistency and compliance throughout the shipping of your waste.
Once fully implemented, this new system will still require that some paper be used for every shipment. For example, the Department of Transportation (DOT) will still require the paper manifest to be available with the driver for emergency response purposes.
Our Team is committed to making the transition to the e-Manifest system as easy as possible for our customers and our TSDF again will continue to accept paper manifests after June 30th. By continuing to use paper manifests, generators will not experience any changes in manifest preparation when the program launches.
We appreciate the confidence you have placed in us and will continue to do all that we can to meet, and hopefully exceed, your expectations. As always, our goal is to combine compliance and customer service! Please do not hesitate to call with questions.
The Pinnacle Team