1. Electronic Manifesting (e-Manifest)
40 CFR

2. 10/5/12 2/7/14 4/16/16 1/3/18 6/30/18 Background
Hazardous Waste e-Manifest Establishment Act
10/5/12
Part 1 of 2 (“One Year Rule”)
2/7/14
EPA assembled an advisory committee
EPA Chair, 2 IT, 3 industry users, 3 state program
Meetings in January and September 2017
4/16/16
Part 2 of 2 (“Fee Rule”)
1/3/18
Effective Date
6/30/18

3. One Year Rule
79 FR 7917
Established legal & policy framework for use of e-Manifests
Purpose:
Identify scope of users and manifests eligible to participate in system
Consistent implementation of e-Manifests in all states
Finalize EPA’s decisions to establish a national e-Manifest system
Announce policy decisions related to using and implementing e-Manifests

4. Notes No opt-out option
All data will be stored in EPA’s system, regardless of submission type
TSD is directly invoiced and pays all fees
Everything that requires a manifest today is included
even PCBs, state-only wastes
e-Manifest does not replace/eliminate biennial (or annual) hazardous waste reports
On EPA’s to-do list for a future addition

5. Notes Transporter to maintain a printed manifest of any type
DOT requirement
Data published 90 days from TSD receipt
Certain CFATS related data will be “sanitized”
P and U listed only
Scrubbed of most shipment-specific details
Brokers are acceptable
Addendum in new
Functionality not yet active

6. User Fee Rule for e-Manifest
83 FR 420
Methodology for setting and revising user fees
Costs for developing, operating, maintaining and upgrading system
Costs incurred in collecting and processing data, subject to change
Type
Option
Details
Full Electronic 1
Electronic from start to finish
All parties registered for e-signature
Hybrid Electronic 2
Generator uses paper, transporter digitizes
Transporter and TSD register
Data plus Image 3
Paper until TSD, TSD uploads data and image
Only TSD must register
Image Only 4
Image, but no data, uploaded, registration unknown
Mailed Paper 5
Mail to EPA, no registration

7. New Paper Manifest ( )
83 FR 420
5 Parts – updated distribution (currently 6)
Page 1 – Designated facility to EPA’s e-manifest system (top copy)
Page 2 – Designated facility to generator
Page 3 – Designated facility copy
Page 4 – Transporter Copy
Page 5 – Generator’s initial copy (bottom copy)
NOTE: TSD does not send any paper manifests back to the generator, States can still require distribution of the generator copy (Footnote 7, 83 FR 437)

8. System Development Web portal to use the system
40 CFR
Web portal to use the system
direct interfaces for third party software access
System under active development, isn’t finished
System integrates
RCRAInfo for registration
CDX for signature management
EPA encouraging people to use system in test environment

9. Software Release Timeline
e-Manifest Release 1.0
Web application and user admin
June 2017
e-Manifest Release 2.0
Industry services, e-signature, payment integration
January 2018
System Launch
June 2018

10. User Roles/Permissions
40 CFR
Site Manager: facility gate keeper
Administers authorized users for a site
EPA recommends 2 per facility
Certifier: full authorization plus ability to certify info for submission
Preparer: view, add and modify but can not submit information
Viewer: only able to view information in system, unable to add, modify or submit

11. E-Signatures e-Signature must be CROMERR compliant
40 CFR
e-Signature must be CROMERR compliant
Cross Media Electronic Reporting Rule, 10/13/05 FR
These signatures have extra security requirements
Traditional tablet-based signatures are technically allowed
None have been approved
Must use EPA’s web portal to e-Sign
This will be an awkward process at best for real-life shipments
If you start a manifest shipping transaction electronically, it stays electronic until the transaction is completed (usually TSD signature).  Similar for paper TSDs will most likely be required to load both the final manifest electronic data and manifest images (for wastes shipped on paper).
System will not eliminate or replace biennial/annual hazardous waste reports.
Huge effort to get up and running in this time period, and there are a few things on the biennial reports that aren’t captured on paper manifests today.
The E-manifest system will take care of manifest distribution (saving mail costs), have reporting facilities, auditing capabilities for changed items, etc…

12. Where are We?
We (and other large TSDs) are very skeptical that EPA will be ready on 6/30/18
Software is very much a beta product
Beta testing scheduled to start 4/23/18
We are actively developing integration with our own systems and will be ready by 6/30/18
At least one of the submission methods (data plus image) has a near-zero impact on current process
Everything stays on paper, and TSD does all work

13. Can I Register?
FYI - Can I register is whether you can register on the production side of the system.  Anyone can register in their test system.  Note – registering in test does not register you in production

14. Best Practices… so Far
Encourage at least 2 people in compliance management register in the RCRA Info portal in the Site Manager role
Will be required to:
Administer sub-user accounts (not available)
E-sign and correct manifests
Assign broker privileges (not available)
See manifests as soon as they are posted (vs. waiting 90 days for public availability).

15. Resources Available Submit input/questions to eManifest@epa.gov
Subscribe to ListServ
send a blank to
Visit EPA’s Manifest Program webpage:
Testing Platforms/Webinars/EPA Regional meetings
FAQs

16. Thank You