&EPA
e-Manifest
Office of Resource Conservation and Recovery | www.EPA.Gov/e-MANiFEST | June 2018
e-Manifest Fact Sheet: Inspectors
EPA is establishing a national system for tracking hazardous waste shipments electronically. This system known as
"e-Manifest," will modernize the nation's cradle-to-grave hazardous waste tracking process while saving valuable time,
resources, and dollars for industry and states. EPA is establishing e-Manifest per the Hazardous Waste Electronic Manifest
Establishment Act, which Congress enacted into law on October 5, 2012. e-Manifest is a multi-faceted program that
includes system development; regulation and policy; implementation and communication; and consultation with the
e-Manifest federal advisory committee.
What Inspectors Need to Know	Scope of e-Manifest
•	e-Manifest launches on June 30, 2018.
•	Users in the regulated community will have the option
to use electronic manifests or continuing to use paper
manifest forms.
•	e-Manifest is a module within RCRAInfo (RCRA
Information System) (Version 6).
•	Beginning on June 30, 2018, receiving facilities must
submit all manifests, including electronic and paper
manifests, to EPA's e-Manifest system.
•	Manifests initiated prior to June 30, 2018, and other
documents, such as the one-time notification for Land
Disposal Restrictions, as well as export manifests, will
not be incorporated in the system.
•	Electronic manifests are the legal equivalent to paper
manifests when obtained, used, and submitted in
accordance with the e-Manifest regulations.
•	Any requirement in the Resource Conservation and
Recovery Act (RCRA) regulations to give, provide,
send, forward, or return a copy of the manifest to
another person (including states) is satisfied when an
electronic manifest is submitted to the system.
•	Entities who register with e-Manifest can use the e-
Manifest system to meet the recordkeeping
requirements and can print a copy of requested
manifests for inspectors during inspections.
•	Generators who do not register with e-Manifest, and
thus are unable to view their manifests in EPA's e-
Manifest system, will be required to obtain paper
copies of their manifests from their receiving facilities
to meet recordkeeping requirements.
•	State inspectors and EPA inspectors will be able to
view manifests for all states through RCRAInfo.
e-Manifest will facilitate the electronic transmission of the
uniform manifest form, which accompanies shipments of
hazardous waste. e-Manifest affects any regulated waste
shipped on a manifest, including:
•	RCRA federal hazardous waste,
•	Regulated PCB waste shipped on a manifest,
•	State-regulated hazardous waste (if manifest is
required by origination or destination state),
•	Very Small Quantity Generator waste (if manifest
required), and
•	Imported hazardous waste.
EPA will implement e-Manifest regulations until Resource
Conservation and Recovery Act (RCRA) authorized states
adopt and become authorized for the e-Manifest
regulations. (Note: some parts of the e-Manifest
regulations, such as collection of user fees, will only be
implemented by EPA.)
The e-Manifest system allows for three types of hazardous
waste manifest creation options:
•	Paper (generator, transporter, and receiving facility all
sign on paper)
•	Hybrid (starts as an electronic manifest, which is
printed and signed by the generator (and transporter)
on paper, and then is signed electronically by the
transporter and all subsequent handlers, including the
receiving facility)
•	Electronic (created in e-Manifest and electronically
signed by all entities listed on the manifest)

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How Inspectors Will Be Impacted
What All Inspectors Need to Do
•	Once the system is populated, inspectors will be able
to:
o perform manifest reviews prior to conducting an
on-site inspection, and
o obtain copies of the manifests prior, and
subsequent, to the inspection.
•	Inspectors can still verify that facility personnel are
meeting the recordkeeping requirements (see also
"Access to Manifest Copies" graphic below).
o For paper manifests, facility personnel can either
maintain paper copies of manifests, or they may
have an e-Manifest account and have the ability to
view their manifest copies (scanned images) in
EPA's e-Manifest system,
o If generators do not have an e-Manifest account,
they must retain paper copies of manifests,
o Generators with e-Manifest accounts can use their
account to view and store their final copies of
paper manifests that are signed by facilities and
uploaded to the system as scanned images. They
can also use the system to view and store all
electronically signed manifests in the system,
o In addition, generators using hybrid manifests
must keep on site the paper copies of their signed
paper manifests.
•	If you do not already have an account for RCRAInfo
(Version 6), you will need to register as a Regulatory
Agency User to access e-Manifest
(https://rcrainfo.epa.goV/rcrainfoprod/action/secured/l
oqin).
•	Provide compliance assistance to regulated entities to
support implementation of e-Manifest and support
adoption of electronic manifests.
•	Become familiar with e-Manifest resources, such as
FAQs, fact sheets, and state and EPA Regional points
of contact.
Federal Links
•	For more information on EPA's e-Manifest Program
and frequently asked questions go to
http://www.epa.gov/e-manifest
•	Submit input/questions to eManifest@epa.gov
•	To subscribe to the general program Listserv send a
blank message to: eManifest-subscribe(a>lists.epa.gov
•	To register for RCRAInfo Version 6 (Production) go to:
https://rcrainfo.epa.goV/rcrainfoprod/action/secured/l
ogin
Access to Manifest Copies
Did the entity sign electronically?
j No
Is the entity a receiving facility?
No
Is the entity a generator who is
using hybrid manifest?
I
No
Is the entity a generator who is
registered for e-Manifest?
No
Yes
Yes
Yes
Yes
Copy available in e-Manifest system.
Keep paper copy of manifest until final copy is
loaded into e-Manifest system.
Keep paper generator copy of manifest for three
years. Keep final copy of manifest from receiving
facility for three years, unless and until generator
can access copy in e-Manifest.
Keep generator copy of paper manifest until final
copy is loaded into e-Manifest system.
Keep generator copy until final manifest copy sent
back from receiving facility. Then keep final
manifest copy for three years.
530-F-18-011

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