Update: U.S. EPA e-Manifesting System

The U.S. EPA e-Manifesting System became effective as of June 30, 2018. This new system stems from the 2012 Hazardous Waste Electronic Manifest Establishment Act. It was created with the goal of reducing costs and improving the quality of oversight and data recording. The e-manifesting system impacts all handling companies that require a Resource Conservation and Recovery Act (RCRA) manifest for their waste. Waste receiving facilities must now submit copies of manifests to the EPA within 30 days of receipt and will pay an estimated processing fee between $4 and $20.

Notably, if a receiving facility handles waste from a different state, and the state of origin requires an RCRA manifest for the waste, the facility must submit a manifest. It does not matter if the receiving facility is in a state that does not consider the waste to be hazardous.

The e-manifesting system was created to eliminate the use of paper manifests, but this transition will occur over the next three years. To assist transition to the new system, the EPA has granted an extension of the 30-day dead line for paper manifests received between June 30, 2018 and September 1, 2018. These manifests must be submitted no later than September 30, 2018. After this grace period, the 30-day limit will be enforced for electronic and paper manifests. It is important to become familiar with the system because failure to comply will result in penalties.

As with any regulation, the cost of non-compliance is ultimately far greater than the cost of compliance.  An option Red Flag Reporting provides with our employee hotline service is a reporting channel that empowers employees to speak-up, anonymously or not, if they witness improper disposal.