The EPA has moved one step closer to implementing an electronic manifest (e-Manifest) system intended to replace the existing paper manifest system used for cradle-to-grave tracking of hazardous waste. Specifically, the Agency is proposing a methodology for imposing fees on users of the e-Manifest system. The fee would cover the use of either e-manifests or paper manifests. Paper manifests would need to be manually inserted into the e-Manifest system, and to encourage a full transition to e-manifesting, the proposal would impose higher costs on generators or handlers who continue to use paper manifests. The fee would apply to each electronic or paper manifest used and submitted to the system.
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EPA’s hazardous waste manifest affects approximately 80,000 federally regulated entities and an equal or greater number of entities handling state-only regulated wastes subject to tracking via the federal manifest. About 45 affected industries ship off-site, transport, and receive several million tons annually of hazardous waste. The EPA estimates that these entities currently use between 3 million and 5 million hazardous waste manifests and continuation sheets to track Resource Conservation and Recovery Act (RCRA) hazardous and state-only regulated wastes from generation sites to receiving facilities for their management.