What EPA's New e-Manifest System Means for Businesses in Every Industry

While the e-Manifest is overall beneficial for the entire waste management industry, there is a lot to understand about the new system and other ever-changing regulations.

Companies in every industry generate hazardous waste – from leftover ink at a printer to scrap tires and spent batteries in auto work. Complying with the ever-changing, complicated requirements for disposing of generated waste can be a daunting task for those who aren’t experts in the field.

Businesses are now affected by a national system recently established by the Environmental Protection Agency (EPA). Known as the Hazardous Waste Electronic Manifest Establishment Act, or e-Manifest, the system tracks hazardous waste shipments electronically in an effort to avoid hazardous substances’ incorrect disposal and environmental impact.

By transitioning from a paper process to an electronic system, EPA estimates the e-Manifest system will ultimately reduce the burden of the uniform manifest form, which must accompany shipments of hazardous waste by law, by up to 700,000 hours, saving state and industry users an estimated $75 to $90 million annually.

But what are the immediate implications for businesses? What do they need to know about the system to avoid penalties? Key topics waste industry executives need to know are outlined below.

What is the e-Manifest System?
Enacted by Congress in 2012, the e-Manifest required EPA to establish a national electronic manifesting system to reduce waste management costs, as well as improve regulatory oversight and data quality.

The e-Manifest creates a centralized national manifest database that can be accessed in real-time by the regulated community. The system modernizes the nation's "cradle-to-grave" hazardous waste tracking process while saving valuable time, resources, and money for industries and states. Additionally, the e-Manifest eliminates the need for generators; transporters; and treatment, storage, and disposal facilities (TSDFs) to provide manifest information to state regulatory agencies, because those agencies will now simply access that information in the national e-Manifest system online.

EPA launched the e-Manifest system on June 30, 2018. Although it was established this summer, EPA will not phase out paper manifests completely until June 30, 2023.

What is the Cost?
EPA has released the following final fee schedule for the e-Manifest system:

  • $15 per manifest: Paper copy mailed from TSDF to EPA; EPA enters all data points into e-Manifest system.
  • $10 per manifest: PDF of final manifest uploaded by TSDF to e-Manifest system; EPA enters all data points.
  • $6.50 per manifest: PDF of final manifest plus API file of all manifest data points uploaded to e-Manifest system.
  • $5 per manifest: API file of all manifest data points plus Cross-Media Electronic Reporting Rule (CROMERR)-compliant signature files uploaded to e-Manifest system.

The fee schedule will be in effect until Sept. 30, 2019. The fees will be invoiced to the TSDF on a monthly basis for each manifest submitted to the e-Manifest system based on the format of submittal outlined above. The TSDF has 30 days to submit the information to the EPA system after signing off. Within 90 days, EPA will make that information available to the public.

Some waste management companies are billing costs back to their customers for using the EPA database and inputting all data manually. When working with a regulated waste management solutions provider, consider one that is using its own systems to prevent additional costs.

What Businesses Are an Exception to e-Manifest?
The e-Manifest requirements only apply to wastes that are required by federal or state regulations to ship on a hazardous waste manifest. Because Very Small Quantity Generators (VSQGs) are not required to ship on a hazardous waste manifest, VSQG waste is federally exempted from e-Manifest submission requirements.

However, there are a handful of states that do require waste generated from VSQGs to ship on a hazardous waste manifest. Some states also require waste shipped to a TSDF located in their state to be shipped on a hazardous waste manifest, regardless of whether the generator is a Large Quantity Generator (LQG), Small Quantity Generator (SQG), or VSQG.

Therefore, while all LQG and SQG waste is always subject to e-Manifest requirements, VSQG waste requirements vary by location. Working with a company that specializes in environmental and regulated waste management can help businesses feel confident in their generator status, help alleviate confusion, and keep that business at zero non-compliances.

How Do I Remain Compliant?
While the e-Manifest is overall beneficial for the entire waste management industry, there is a lot to understand about the new system and other ever-changing regulations. One of the most important things a business can do to remain compliant is to find an experienced third-party regulated waste management solutions provider.

These companies help businesses stay safe and follow proper procedures for managing their waste in various ways, which may include sending legislative update reports outlining any regulatory changes, big or small, that may affect their workforce according to their generator status and location.

Navigating new regulations is difficult for businesses of every size, so it is important for businesses to find the best regulated waste management solutions partner before they are hit with a non-compliance or fine, rather than waiting until the damage has been done to their business' reputation or the environment.

Maricha Ellis is vice president of marketing and sales operations for Stericycle Environmental Solutions, a leader in assisting customers with hazardous waste transportation and disposal, industrial cleanup, household hazardous waste, site restoration, emergency response services, and more. Stericycle is ready to comply with the e-Manifest requirements and meet the needs of its customers. For more information, visit www.stericycleenvironmental.com.