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EPA’s e-Manifest Fees Doubling

Authored by Angie Martin, PE, CHMM

EPA’s e-Manifest processing facility received over 1.5 million manifests from the launch of the system on June 30, 2018 through April 30, 2019. On an annualized basis, this number falls 880,000 manifests short of the projected number of manifests initially used to calculate EPA’s e-Manifest fees. The regulations require EPA to recalculate fees which are effective October 1, 2019 and every 2 years thereafter. EPA has increased fees for different types of manifest submissions from 60% to 115%. These fees are charged directly to the destination facilities. As such, Heritage is adjusting our e-Manifest fee to $25 per manifest, effective with shipments originating on October 1.

As noted below, EPA’s analysis indicated that a very low percentage of manifests have been submitted using fully electronic options (<0.3%).  This is due to a wide variety of factors (user registration, continuing software changes, technical restrictions, logistical challenges, etc.) and was the primary topic of the recent Advisory Board meeting.  EPA also has a backlog of approximately 100,000 paper manifests to process and about 270,000 data plus image manifests to process. 

At this time, Heritage submits manifests to EPA using the same two most widely used options indicated below (scanned image and data plus image). 

Manifest Submission Type Submitted (6/30/18 – 4/30/19) %
Mailed paper manifest 103,348 6.8%
Scanned image upload 272,627 18%
Data plus image 1,140,003 75%
Fully electronic 4,005 <0.3%

Source: EPA, “Hazardous Waste e-Manifest Advisory Board June 2019 Meeting Background Whitepaper.”


Heritage is committed to safely and compliantly transporting, managing, and disposing of our customers’ waste.  We will continue to follow the EPA’s progress on e-Manifest programming and implementation and to update our customers on the progress.  EPA will recalculate fees in 2021, effective October 2021.

e-Manifest Summary

The Hazardous Waste Electronic Manifest System  

As many of you are aware, effective June 30th of this year, EPA will launch an electronic manifest (e-Manifest) system.  Rest assured that Heritage has been diligently participating in the implementation process.  Presently, EPA continues active development on the e-manifest system, prompting Heritage to choose continued use of paper manifests to manage waste shipments until full electronic implementation is feasible.  Paper manifests are the least disruptive and have the lowest impact on the hazardous waste generator community.  Heritage will continue to return your completed manifest in the same manner as you receive it now.  In addition, you will continue to have access to your completed manifests in our EIS system.

Heritage will offer a fully electronic manifest option when it is prudent considering our dedication to our core value of “Safe and Compliant or Not at All,” with our primary goal being to safely and compliantly manage the shipment of your hazardous wastes.

 

e-Manifest Options

EPA has provided Options for manifest submission as listed below:

  • Option 1: Completely electronic manifest;
  • Option 2: Hybrid manifest, which starts on paper and the transporter converts to electronic;
  • Option 3: Paper manifest to the TSD, where the TSD submits data and a manifest scanned image after shipment is complete;
  • Option 4: Scanned copy of the manifest with minimal data uploaded; or
  • Option 5: Paper copy mailed directly to EPA.

As explained above, at this time we have selected Option 3 from EPA’s acceptable list, where the TSD facility performs nearly all of the “electronic” parts of the e-Manifest process.

 

Signature Issues

Option 1 manifests require CROMERR signatures by all parties.  This type of signature is more than using a conventional tablet to sign your name.  EPA will provide a web-based application that supports electronic signatures.  However, this requires the completion of a registration process for the electronic signers.  Additionally, while there will be a mechanism to copy a previous manifest in the EPA’s e-Manifest system, it does not accommodate the electronic waste profile information that Heritage has in our system.  Heritage is developing a fully electronic manifesting system which will allow our customers to configure manifests online, much like our current ordering capabilities.

 

Continuing Paper Requirements

The e-Manifest system will still require that some paper be used for every shipment, even for the completely electronic Option 1.  The requirement for paper land disposal restriction forms to accompany at least the first shipment of a new wastestream has not been removed.  DOT requires paper to be available with the truck driver for emergency response purposes.  The transition to a completely paperless shipment mode will require additional regulatory actions from both DOT and EPA.  EPA is replacing the current 6-part manifest form with a 5-part form that allows for the change in distribution requirements.  However, EPA has also stated that existing 6-part forms will be accepted after June 30th — allowing for usage of existing stock and the ability to obtain the new form from approved printers.

 

Fees

The EPA will charge e-Manifest fees directly to the TSD facilities. These fees are associated with recovering EPA’s development expenses and maintaining EPA’s operating budget for the e-Manifest program.  Heritage has and will continue to invest heavily in software and hardware development to ensure e-Manifest implementation is seamless to our customers.  Heritage will apply a $15 fee per manifest to cover federal fees and our development and maintenance costs.

 

Registration

No actions are required on your part for the Option 3 manifest process Heritage will initially employ.  However, e-Manifest registration is strongly recommended and does offer several benefits.  In particular, registration will allow generators to view all manifest data as soon as it has been uploaded to EPA by Heritage.   EPA and Heritage are encouraging generators to register at least two Site Managers per location.  If you want to “test drive” the e-Manifest today, you can do this but must register in EPA’s test system.  After June 30, you will need to be registered in the production e-Manifest system.  Registration in the test system does not transfer to the production system.

 

In Closing

Heritage will continue to provide updates about e-Manifest and will provide webinar training well before our customers are required to make changes to their waste manifesting processes.  But remember that on June 30, 2018, nothing will change for Heritage customers.