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Dakota Software's Blog for EHS and Sustainability Professionals

The New e-Manifest System: 5 Things to Know

July 24th, 2018

The New e-Manifest System: 5 Things to Know

After more than 6 years of development, the U.S. Environmental Protection Agency’s (EPA) national e-Manifest system launched on June 30, 2018, in all 50 states. Revised regulations are in place and the new system has been tested by users.

The manifest regulations still require all waste handlers (generators, transporters, and receiving facilities) to keep records of their manifests as evidence that the signatures of each of the parties were involved in the entire chain of custody. When all parties use an e-Manifest, these records are maintained within the e-Manifest system. It becomes a bit tricky for generators that continue to use paper manifests and even trickier if they have not registered with the e-Manifest system and created an account for monitoring manifest activity.

Needless to say, a lot of affected businesses still have questions. Here are 5 key things to remember.

  • Paper Isn’t Dead … Yet

    Of course, paper manifests still exist—and they may still be used, but not for too much longer (3–5 years). There’s a new manifest in town, however—a version that consists of 5 copies rather than 6. It’s called EPA Form 8700-22 (Rev. 12-17) and (despite the date) is the most recent edition of the form. (Keep in mind that the EPA has indicated that this new 5-copy form is not likely to be available for use from most printers until around September 1, 2018.)

    But can you continue to use that stack of 6-copy manifests? Well, the EPA at first said that only the new manifest could be used after June 30, 2018, and that the “use of any earlier editions is prohibited.” But the Agency recently said that existing stocks of 6-copy manifests can be used provided that the distribution information specified on the top copy of the new 5-copy edition is added to the top copy of the older 6-copy edition. That information, in the lower right-hand corner of the top copy, reads, “Designated Facility to EPA’s e-Manifest System.”

    How should this information be added to 6-copy manifests? The EPA has no preference, as long as confusion is minimized. However, the Agency’s suggestion that an adhesive label with the preprinted distribution language be applied to the lower right-hand corner of the top copy is probably the best way to go.

    It seems easier to just go digital!
  • Manifest Corrections Are A-OK—But You Need to Register

    One of the features of the e-Manifest system is that any party in the chain of custody can submit data corrections to the system, at any time after the receiving facility has submitted its signed copy of the manifest to the system. This allows waste handlers and generators the opportunity to approve or track post-receipt data corrections electronically. Waste handlers must certify that the data as corrected is accurate and complete. Remember, you can neither see the electronic manifest nor correct it unless you are registered in the e-Manifest system.

    Note that because this data correction process will not be implemented until fall 2018, any corrections needed for manifests previously submitted cannot be made until that time. Of course, corrections can still be made on paper forms used in this time period.
  • Receiving Facilities Still Have Time

    Some handlers of hazardous waste manifests continue to struggle to be in compliance with the new requirements for e-manifests. This has been especially true for receiving facilities, many of whom have not yet completed the steps necessary to modify their software system and integrate it with the e-Manifest system.

    With this in mind, the EPA will allow receiving facilities until September 30 to submit all paper manifests they received between June 30, 2018 and September 1, 2018. That’s 60 additional days for receiving facilities to submit their paper manifests. The idea is that the additional time should allow receiving facilities to complete their software upgrades and e-Manifest system integration.

    While the extra time is no doubt a most welcome one, remember this submission extension is only temporary—paper manifests received after September 1, 2018, must be submitted to the EPA within 30 days of receipt, as required by the regulations.
  • Switching to Digital Saves Money on Fees

    A lot of receiving facilities didn’t view adapting to the e-manifest system as a technical hurdle but a financial one—the EPA charges receiving facilities a user fee for each manifest submitted. The highest fee is for mailed paper manifests; a lower fee is charged for uploads of scanned images such as Adobe PDF files; a lower fee still applies to manifests submitted as data files (such as JSON files) plus scanned images; and the lowest fee is charged for a fully electronic manifest or a “hybrid” manifest (i.e., those manifests that begin with the generator as a paper manifest and then are converted to an e-Manifest by the receiving facility).

    The EPA recently announced the user fees that will be in effect from June 30, 2018, through September 30, 2019—take a look at the chart below to see what fees might apply to your operations.

    Manifest Submission Type | Fee per Manifest

    Mailed in Paper Manifest | $15.00
    Scanned Image Upload | $10.00
    Data + Image Upload | $6.50
    Electronic Manifest (Fully Electronic & Hybrid) | $5.00
  • It’s All Very Complex—and Software Can Help

    If you’re still scratching your head after all of this information, it’s understandable—and you’re definitely not alone! To help ease the burden of compliance, software such as Dakota Software’s Waste Management Solution seeks to simplify the complex logistics and detailed recordkeeping associated with managing solid and hazardous waste.

understanding-eps-new-emanifest-system-dakota-software

With a waste management application, EHS professionals and their organizations can maintain control from the time of waste creation to disposal—and all points in between. With flexible configurations, dashboards to help with organizing and tracking manifests, and alerts and notifications at just the right times, it takes the guesswork out of compliance—and boosts organizational success.

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