New Hazardous Waste e-Manifest System Begins 6/30/18

Texas Hazardous Waste Disposal Update

The US Environmental Protection Agency is launching their new Electronic Manifest System (e-Manifest) tomorrow, June 30th, 2018.

The new system is called the Hazardous Waste Electronic Manifest Establishment ACT, and became law on 10/5/2012. The system is designed to simplify and streamline the management and tracking of hazardous waste shipments across the US via the “eManifest” system.

This new system impacts all generators of non-hazardous and hazardous waste materials, hazardous waste transporters and waste treatment facilities (TSDFs).

The system provides for 4 different manifesting methods:

Paper manifest submitted to EPA
PDF image of the manifest submitted electronically
Data file and PDF image of the manifest submitted together
Manifest created in e-Manifest system

The eManifest system has associated costs which will be passed on to generators of hazardous industrial waste via new nominal fees, which will range from $10 – $20 per manifest. The fees are intended to cover administrative, operational, maintenance and upgrade costs for the system. TSDF (hazardous waste treatment and storage facilities) will collect these fees from generators and forward to EPA.

Most TSDFs will support the paper manifest option for an initial time period to help facilitate transition and adoption of the new program. For this option, hazardous waste generators will continue use of paper manifests, but the new forms will include only 5 pages instead of the current 6 page format. Generators will still sign manifests the same way as with the previous manifest form, may still be required to provide copies to their state environmental agencies (depending on the state) and must maintain paper copies on file for 3 years.

The new eManifest system cannot automatically validate paper manifest data such as DOT proper shipping names, EPA hazardous waste codes, state waste codes, transporter, generator and TSDF EPA ID’s, DOT container types, quantities, etc.. Therefore each receiving TSDF will be responsible for validating all such information prior uploading into the new eManifest system to ensure compliance with environmental, DOT and safety regulations.

TSDFs will then process the paper manifest form by providing electronic signatures and then enter them into the eManifest system (“CDX” system).

Some TSDFs will also initially support the other 3 “hybrid” and full electronic manifesting options described at the beginning of this post. For the “hybrid” option, the original manifest will be created by the TSDF in the eManifest system, and then printed on paper for use by the transporter and signature by the waste generator. (These paper copies must still be retained on file for 3 years by the waste generator, the same as the original paper manifests). Upon receiving the waste shipment, the TSDF will then electronically sign and transmit the manifest using the CDX electronic system. This process may require additional or higher fees than the paper method due to complexity. Most TSDFs have still not determined actual costs for this option

The good news is that given the option to continue using paper manifests (for whatever that time period might be), the transition to the new eManifest system should be relatively seamless and simple for most waste generators.

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By Russell Carr|2022-03-21T13:01:29-05:00July 1st, 2018|Fed Regulation, Government Regulation, Hazardous Waste Management, Texas Environmental Regulations, Texas Hazardous Materials Regulations|Comments Off

About the Author: Russell Carr

How A Sales Guy Transformed Into An Environmental, Health & Safety Expert & Advocate For Small Businesses I've spent my entire 30+ year career working within the manufacturing and “industrial services” sectors. The first 15 years of my career focused on sales of hazardous materials related products and services to the manufacturing sector, then for the last 16+ years transitioned into entrepreneurship, founding 3 small industrial services related contracting businesses. As you’ll see below, running these companies eventually lead me to found yet a 4th business, but more on that in a minute…. Here’s a brief description of the first 3 companies: Berg Environmental Services, Inc.: hazardous waste disposal & transportation services, founded in August of 2003 3rd party wind energy operations & maintenance services provider to utility scale wind farms throughout the US, founded in September 2007 3rd party oil & gas exploration & production services provider, founded in August of 2011 Each of these companies operated in extremely dangerous working conditions and exposed my employees to a wide range of serious health & safety hazards on a daily basis. To complicate matters, 2 of the companies also exposed the environment to significant potential harm. In other words, I learned very early the critical importance of managing environmental, health and safety issues so as to ensure the safety of our employees and the environment, as well as minimizing related risks. But I also learned how incredibly difficult and challenging this endeavor can be due to the wide range of complicated and continually changing environmental, health and safety rules and regulations that impacted the companies. To summarize the challenges: First I had to determine which regulations applied to each company, then I had to build compliance programs to meet those regulations, and finally I had to ensure that the programs were being managed and followed by our staff on a daily basis. All while trying to run and grow 3 profitable businesses…. It was overwhelming and I always struggled to keep up. To make matters worse, throughout this time I also witnessed the devastating price that companies, management and ownership can pay for failing to manage EHS compliance. This included seeing one of my hazardous waste management clients get sent to jail over environmental issues, another client’s management team threatened with jail time, a direct competitor get fined $378,000 by OSHA fine after an employee was nearly killed, and many others face major fines and penalties. Full disclosure, one of my companies got fined by OSHA at one point, & another was cited by TCEQ, so I know how it feels. In summary, I learned first hand how incredibly difficult it is for small companies to manage EHS compliance due to a common lack of the critical expertise, time and resources that are needed to keep up, and how this situation then ends up exposing them to these potentially catastrophic risks that can literally destroy lives and businesses. This later inspired me to found my 4th company, Berg Compliance Solutions in 2012, which is dedicated to helping other small businesses, and business owners, to manage EHS compliance and risk. Education BA, Philosophy, University of Colorado, Boulder, December, 1990. Summary of Professional Experience & Qualifications: 30+ years serving the manufacturing & industrial services sectors 30+ years of sales and marketing experience 16+ years as small business owner & entrepreneur: Founded and operated 4 small businesses since 2003. Environmental, Health & Safety Compliance & Program Related: 19 plus years of hazardous waste management including EPA, TCEQ & RCRA regulations 8 years of DOT/FMCSA compliance experience, including hazardous materials transportation 8 years of combined experience implementing and managing OSHA health and safety compliance programs for 2 high risk energy services businesses Successfully implemented and gained ISO 9001 Quality Management Certification and OHSAS 18001 (Occupational Health & Safety Advisory Service) Certification for wind energy maintenance business. Regulatory Enforcement Related Experience: Served as expert witness in criminal environmental compliance enforcement cases Superfund-CERCLA OSHA enforcement inspections, investigations and resolution in following industries: industrial services, manufacturing & construction. TCEQ enforcement inspections, investigations and resolution in manufacturing.

New Hazardous Waste e-Manifest System Begins 6/30/18