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The New Federal Hazardous Waste Electronic Manifest

California CUPA Conference – February 5, 2018

Cheryl Nelson (USEPA), Fred Jenkins (USEPA) and Valetti Lang (DTSC)Slide2

Presentation Outline


Benefits of e-Manifest

How e-Manifest Works

Implementation and Communication

e-Manifest Outreach

e-Manifest in California

Getting Started


e-Manifest BackgroundSlide4

Hazardous Waste Manifests: e-Manifest

e-Manifest is a new national electronic manifest system that will facilitate electronic creation and transmission of hazardous waste manifests by industry.

A new industry appl

ication (Application Programming Interface (API)) will

allow hazardous waste handlers to create and manage hazardous waste manifests directly in EPA’s National database (


) from their systems.Site Managers will be responsible for approving user registrations for users at their facility/company.The e-Manifest system was established by a new statute and regulations:Hazardous Waste Electronic Manifest Establishment Act of 2012e-Manifest One-year Rule: February 2014e-Manifest User Fee Rule: January 2018Slide5

Hazardous Waste Electronic Manifest Establishment Act

October 5, 2012: President Obama signed into law the Act authorizing EPA to implement a national electronic manifest system.

Key Features of the Act:

Extends to all federally

and state-regulated

wastes requiring manifests.

The use of electronic manifests is optional for users, and authorizes central collection of data from electronic and paper manifests.EPA is authorized to collect reasonable user fees for all system related costs including development and maintenance.EPA must conduct annual Inspector General (IG) audits and submit biennial reports to Congress.

EPA must establish a

uniform effective date

in all states for e-Manifest, and must implement e-Manifest until States are authorized.Slide6

e-Manifest One-Year Rule

Act required EPA to issue implementing regulations within one year.

Agency issued its "One-Year Rule

" on February 7, 2014.

Key elements of the One-Year Rule:

Legal framework for use of electronic manifests: Use electronic manifests per conditions of rule, and they shall be the legal equivalent of the standard paper forms.

Codified Act's terms on scope and consistent implementation in states.Finalized EPA decision to establish a national system to be hosted by EPA.Slide7

e-Manifest User Fee Rule

Agency issued its final User Fee Rule

on January 3, 2018

Key elements of the User Fee Rule:


receiving facilities

to submit manifests to EPAEstablishes the fees that will be charged for each manifest submission and how/when the fee formula will be adjustedEstablishes how fees will be paid (using sanctions for non-payment of feesIncentivizes electronic submission of manifests vs paper (i.e., lower fees for electronic submittal)Establishes uniform national effective date (June 30, 2018) and discusses effects on State Programs.Slide8

Where are we now?


Release 2 of the electronic industry application is operational

and available for user testing.

For general Information on how to test the e-Manifest system, see EPA’s website at:

Testers may test with either their handler ID or one of the test sites listed at: (or both)NOW: User Fee Rule is final. June 30, 2018: EPA expects to complete testing and officially launch the e-Manifest system.On this date, receiving facilities will begin submitting manifests, whether electronic or paper, to EPA and will incur user fees.Consistent with the e-Manifest Act, e-Manifest requirements will become

immediately effective in all states

on the system launch date.Slide9

Benefits of e-ManifestSlide10

Benefits of e-Manifest

Over the first six years of system operation, cost savings are expected to equal an annualized $65 million per year.

Once electronic manifests have been widely adopted, annual cost savings are expected to exceed $90 million


Reduces burden for states that currently collect and process manifest data into state tracking systems.

Establishes national data base of shipment/receipt data.

Enhances ability to track and extract data on waste shipments by storing and distributing these data in a central, accessible location. Slide11

Benefits of e-Manifest (Cont’d)

Delivers faster knowledge of the status of waste shipments than under the current paper based system.

Increases legibility of electronic manifest records compared to current paper manifests.Slide12

How e-Manifest WorksSlide13

How Does it Work?Receiving Facilities will be required to submit final signed hazardous waste manifests to EPA and pay a fee.

Facilities can


to submit paper or electronic manifests.

Three types of paper manifests:

Mail in paper submissions

Upload scanned images into e-ManifestInput data directly in e-ManifestFully electronic manifestFees for paper will be higher than for electronic submittals (to incentivize electronic submissions and recover higher marginal costs).Electronic system will allow for corrections/amendments.Once uploaded, all data will be accessible to regulators immediately.Public will have access to data 90 days after upload.14Slide15

Estimated User Fees

Estimated Year One Marginal Cost Manifest Fees

by Manifest Type (2017$)

Manifest Submission Type

Year One Fee


Paper Manifest Types

Mailed Paper


Image Uploads


Data File Uploads


Electronic Manifests

(includes hybrid)


$4.00 Slide16

e-Manifest Initial Focus



: Receiving Facilities (e.g., all facilities that receive Federal OR State-only hazardous waste on a manifest or receive imports) must submit a paper or electronic manifest to EPA and pay an associated fee.


: Any other hazardous waste handler (e.g., generators, transporters, brokers, transfer facilities) can create an electronic manifest in the e-manifest application.

FUTURE:Facilities that export hazardous waste will need to submit manifests to EPA and pay an associated fee.Slide17

Implementation and Communication Slide18

Top 5 Things You Need to Know About e-Manifest

e-Manifest will launch nationwide on June 30, 2018.

e-Manifest will be available for testing, prior to launch, through Spring 2018.


receiving facilities

that receive waste that must be manifested under federal law or receive state-only hazardous waste that must be manifested as required by either the state in which the waste was generated or received, must submit those manifests to EPA either in paper or electronically. EPA will charge receiving facilities an associated fee for each manifest submission.Handlers will be required to register for e-Manifest to submit manifests electronically and to make corrections.Once the system launches, e-Manifest data will be available to the public 90 days post-receipt of the manifest. Slide19

States’ Role in e-Manifest

States play a critical role in ensuring the success of e-Manifest.

EPA sees states as a key partner in communicating and coordinating outreach to their regulated community to ensure a smooth transition to e-Manifest.

EPA places a high priority on tapping the states’ expertise, to ensure seamless data flows from e-Manifest to state databases and in developing reporting functions to maximize the benefits and use of this first ever national repository of manifest data.

EPA needs help from its regional and state partners with successfully implementing e-Manifest.Slide20

e-Manifest Implementation

EPA is collaborating nationally to implement e-manifest:

Identifying key stakeholders and sharing information through webinars, websites, presentations, and fact sheets.

Assisting states with adoption and authorization of e-Manifest regulations (One Year Rule + User Fee rule).

Ensuring that states are preparing to input/receive manifest data to/from the national e-manifest system.

Ensuring that all receiving facilities are aware of the new requirements and preparing to comply.

Ensuring that industry users are registering and testing the e-Manifest system.Slide21

e-Manifest OutreachSlide22

e-Manifest Outreach


EPA is conducting outreach through a number of mechanisms to disseminate information about e-Manifest and coordinate with other stakeholders:

Advisory Board meetings

Monthly webinars

Constant user testing

e-Manifest Website, including FAQsIndustry and state stakeholder meetingsRegional roadshowsMonthly Public Listserv announcementsFact sheets (coming soon!)FUTURE: Help DeskSlide23

e-Manifest Outreach

Submit input/questions to

To subscribe to the ListServ send a blank message to:

For more information on EPA’s e-Manifest Program:

How Will e-Manifest Work in CA?Slide25

How will e-Manifest work in California?

Same as nationally



DTSC will still collect

manifests from generators and transporters

.DTSC will no longer collect manifests from receiving facilities; however, DTSC will continue to use their own State HWTS database and will download receiving facility manifests from e-Manifest to HWTS.E-Manifest will apply to Federal and State-only waste.DTSC is analyzing expansion of HWTS to support electronic manifesting.

To access the State HWTS, go to this link


Getting StartedSlide28

RCRAInfo and e-Manifest

RCRAInfo is EPA’s national database system used to track information provided by the regulated community concerning the generation, shipment, treatment and disposal of hazardous wastes.

e-Manifest was originally envisioned to be a separate system, however, as planning for the system evolved, EPA decided to bring e-Manifest under the RCRAInfo umbrella in order to leverage the RCRA data and foundational components needed to build e-Manifest.Slide29

RCRAInfo Industry ApplicationsThere will be three modules in the industry application of RCRAInfo:


– allows facilities to electronically complete and submit EPA Form 8700-12 to obtain/change an EPA ID Number.

DTSC opted into this application is now accepting user accounts.

Biennial Report

– will allow facilities to electronically complete and submit EPA Form 8700-13A/B, the Hazardous Waste Report (Biennial Report).

DTSC has NOT opted into this application and is instead using its own electronic BR reporting module.e-Manifest –will allow facilities to electronically complete EPA Form 8700-22/22A and submit their manifest data.Any industry users already approved at the Site Manager permission level in either myRCRAid or BR is automatically registered for e-manifest.When it launches in June 2018, e-Manifest will be mandatory for all states.Slide30

e-Manifest: How can Industry Register? Users already registered for either myRCRAid or BR are automatically registered for e-Manifest.

Here is the link for information on how to register in California:

There are several different types of user registration permissions.


Industry Application User PermissionsCurrently, RCRAInfo Industry Application allows for the following user permissions:


Level of Permission



The user has no permissions for these sites within the module specified.


The user can view the data for these sites within the module specified but cannot change the information in any manner.


The user can enter data for these sites within the module specified but cannot sign and submit the information to the regulatory authority.


The user can sign and submit the information for these sites to the regulatory authority. This user is required to obtain an Electronic Signature Agreement.Slide32

Industry Application User Permissions

RCRAInfo –

Site Manager

The new

Site Manager

permission was added to the RCRAInfo Industry Application when the electronic Biennial Report launched in Fall 2017.

Site Managers will be responsible for approving user registrations for users at their facility/company.Site Managers will be responsible for approving user registrations for users at their facility/company.When e-Manifest launches, any existing Site Manager will have full permissions to use the module without undergoing a new registration process.Slide33

How to Stay Informed


EPA Website (actively updated):

Submit input/questions to:

Subscribe to the Listserv, send a blank message to: eManifest-subscribe@lists.epa.govAttend free EPA Webinars; see EPA’s webpage for upcoming webinarsContact Regional POCTo participate in our user testing please visit:


Cheryl Nelson

U.S. Environmental Protection Agency

Region 9

75 Hawthorne Street

San Francisco, CA 94105


Fred Jenkins Jr., Ph.D.

U.S. Environmental Protection Agency



Valetti Lang

State of California

Department of Toxic Substances Control

1001 I Street

Sacramento, CA 95812


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The New Federal Hazardous Waste Electronic Manifest - Description

California CUPA Conference February 5 2018 Cheryl Nelson USEPA Fred Jenkins USEPA and Valetti Lang DTSC Presentation Outline Background Benefits of eManifest How eManifest Works ID: 711998 Download Presentation

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