EPA's Hazardous Waste E-Manifest Requirements Take Effect June 30, 2018

MAY 15, 2018

EPA’s New Electronic Hazardous Waste Manifest Requirements Scheduled to Take Effect June 30, 2018.   

These new E-manifest requirements will apply to all hazardous waste scheduled for receipt or transportation performed after June 30. This new legislation requires hazardous waste Treatment, Storage and Disposal Facilities (TSDFs) to submit manifest data to the EPA for the shipments they receive.  Under this new regulatory requirement, the EPA will archive this data in a publicly accessible E-manifest system and invoice TSDFs a per-manifest fee to fund the development, future upgrades and maintenance of the data base.  

Clean Earth is prepared to comply with all new data submission requirements related to the new E-manifest mandated by the EPA. Below is Clean Earth’s Regulatory overview of our approach to compliance with these new regulations:

Several key details about the logistics of the E-manifest data submission process and the associated fee structure have been proposed but not confirmed by the EPA, including a per-manifest fee structure.   

This fee is contingent upon how the manifest and associated data is submitted to EPA by the TSDF.  

EPA currently plans to publish the final E-manifest fee structure reportedly sometime in early May. 

The expectation is, there will be no change to the current service process. All hazardous waste shipments will continue to be documented on paper manifests, and Clean Earth will submit the required data to EPA for those manifests received at our TSDFs electronically. 

We continue to keep our ear close to the ground and will closely monitor published guidance as received from the EPA to evaluate options for transitioning to a fully electronic manifest process. However, this transition will require complying with detailed software signature requirements that have not yet been fully vetted by EPA.  Clean Earth will not be moving forward with full electronic manifesting until a EPA vetted and sanctioned software solution is in place that will meet all requirements and protect the security of our customers and their electronic data.

DOT will continue to require paper shipping documents until/unless the hazmat regulations in 49 CFR are amended to meet the new E-manifest requirements.  

Clean Earth has assembled a working project team to manage communication, training and data/security related to the new E-manifest requirements. Because final costs have not been realized, Clean Earth is evaluating costs to assess the potential impact to our customers. 

To our valued customers be assured, and as stated above, Clean Earth is monitoring the EPA’s E-manifest communications daily for updated developments and will share these new developments with our valued customers as they become available. We will plan to circulate additional updates in May and early June once the proposed manifest fee structure has been finalized. 

While Clean Earth is committed to complying fully with revised regulations in the most efficient manner. The E-manifest regulations will create additional operating expenses for Clean Earth that are not part of current service offerings.  To account for these operational changes, we will be reaching out to our customers in May/June to discuss E-manifest related fees. 

For additional information pertaining to EPA’s E-manifest regulations, click here.

The EPA’s E-Manifest Project Team has shared FAQs, and has additional answers posted on the e-manifest website.

To submit a question to Clean Earth about e-manifest regulations, contact us at e-manifests@cleanearthinc.com.

Thank You for Choosing Clean Earth.