New Whitepaper! E-Manifest Ruling

For over a decade, the US EPA, states, industry and related stakeholders have had a mutual interest in developing a national electronic manifest system that would facilitate the electronic transmission of the uniform manifest form and make the use of the uniform manifest much more cost-effective and convenient for users [source].

In our newest whitepaper, Heritage Corporate Compliance Program Manager, Terry Ferrill, will walk you through several topics relating to the new system. These topics include the cost of implementation, the centralized system, regulations concerning paper vs. electronic, e-signatures, data security and accessibility, and mail elimination, among others.

If you would like to receive a copy of this new Whitepaper simply click this link E-Manifest Final Rule Whitepaper and you’ll be taken to the download form. Also, if there are any other regulatory issues you would like us to write about please let us know in the comments section!

E Manifest Final Rule Whitepaper

About the Author

Terry Ferrill has been in the environmental and hazardous waste business at Heritage for nearly 30 years. Mr. Ferrill has held positions within Heritage as a consultant, business analyst, and hazardous waste facility compliance manager. He currently works in Heritage’s corporate compliance department, where he specializes in regulatory research to support internal business development and assist customers with thorny compliance issues.

10 Steps to Uniform Hazardous Waste Manifest Completion

This is another excerpt taken from our RCRA training literature. The following is a good list of steps to take to ensure proper hazardous waste manifest completion.

1. Complete all federally required information.

2. Complete the state required information, if any, for the TSD state.

3. Complete the state required information, if any, for the generator’s state.

4. Complete TSD specific information, if any. (For example: a TSD may require waste stream numbers).

5. Review the manifest. Is all information complete and correct? Are all copies legible?

6. Read the generator’s certification and sign the manifest.

7. Complete, review, and sign LDR form, as applicable.

8. Have the first transporter sign the acknowledgement of receipt of materials. Be sure to check that the vehicle placarding and container labels are correct, check container counts and agree with driver.

9. Remove appropriate copies of the manifest. Retain a copy of the LDR, as applicable.

10. File appropriate copies of manifest, a copy of LDR form, and additional documents.

Some Additional Tips

  • After the initial completion of the manifest and subsequent signatures and changes, check to make certain all marks are legible on all copies.
  • Maintain a log, either written or by computer, to track open manifests and manifest document numbers.
  • Corrections that are made should be accompanied by initials and date (ASM 6/30/06). Corrections in type and quantity require contact between the generator and TSD. If these corrections are made by telephone, both parties should date and initial the change.
  • All changes should be made by line out and initials (F006 D008 ASM 6/30/94). Do not use correction tapes or liquids.
  • Maintain a working relationship with government agencies.