Written by: Kyra Ochsner, Environmental Specialist, U.S. Compliance,
Reviewed by: Ellen Hawley, Supervisor – Environmental, U.S. Compliance
On June 28, 2024, The EPA Administrator finalized an amendment to hazardous waste manifest regulations under the Resource Conservation and Recovery Act (RCRA) with the e-Manifest Third Final Rule. This amendment is designed to encourage hazardous waste generators to adopt the electronic Hazardous Waste Manifest system (e-Manifest) to enhance compliance monitoring and improve access to information availability.
What is e-Manifest?
The EPA’s e-Manifest system modernizes the tracking of hazardous waste by replacing the traditional paper-based process. Its purpose remains the same: to document the movement of hazardous waste from its point of generation to its final Treatment, Storage, and Disposal Facility (TSDF). The online system allows for hazardous waste generators, transporters, and TSDFs to electronically create, sign, and submit manifests to the EPA.
Since its launch in 2018, e-Manifest has improved compliance monitoring for regulatory agencies, allowed generators to digitally track the amount and type of waste produced at their facilities, and provided environmental consultants, such as U.S. Compliance, access to waste data from their generator clients.
Summary of the Third Final Rule
The e-Manifest Third Final Rule takes the digitization transition a step further. Small and large quantity generators are now required to register for access to e-Manifest to obtain the final manifest copy from the TSDFs, which includes signatures from the generator, transporter, and TSDF. This replaces the previous requirement that mandated TSDFs to send a paper copy of the 3-signature manifest back to generators. While TSDFs may still choose to provide a hard copy, it is no longer a regulatory requirement
Below are the key points of the Third Final Rule:
- Small and large quantity generators are now required to register for access to e-Manifest to electronically obtain their final signed manifest copies. VSQGs with EPA ID numbers may also register for access.
- Entities are mandated to correct manifest data errors.
- Exception Reports, Discrepancy Reports, and Unmanifested Waste Reports are now integrated into the e-Manifest system.
- Hazardous waste export manifests are included in e-Manifest, with exporters responsible for submitting manifests and paying the applicable user fees.
- The manifest form includes additional fields to expand the required international shipment data elements.
- Movement document requirements have been revised to better align manifest data with movement document data, assisting with the integration of EPA’s Waste Import Export Tracking System into RCRAInfo.
- Changes have been made to PCB manifest regulations under TSCA, along with other technical corrections to remove obsolete requirements, correct typographical errors, establish definitions, and improve alignment with the e-Manifest program.
How Can U.S. Compliance Help?
As we conduct our routine environmental visits for our CaaS (Compliance as a Service) clients, U.S. Compliance will assist with ensuring our small and large quantity generator clients have accounts with RCRAinfo e-Manifest. U.S. Compliance can help clients review the requirements of the new e-Manifest Final Third Rule and provide support in setting up an account if needed. Contact your representative today for assistance.
