&EPA e-Manifest Office of Resource Conservation and Recovery | www.EPA.Gov/e-MANiFEST | December 2020 e-Manifest Fact Sheet: Inspectors On June 30, 2018, EPA launched a national system for tracking hazardous waste shipments electronically. This system known as "e-Manifest," modernizes the nation's cradle-to-grave hazardous waste tracking process while saving valuable time, resources, and dollars for industry and states. EPA established 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 e-Manifest launched on June 30, 2018. Users in the regulated community have the option to use electronic manifests or continuing to use paper manifest forms. e-Manifest is a module within Resource Conservation and Recovery Act (RCRA) Information System (RCRAInfo) Version 6. As of 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, are not 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 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, are required to obtain paper copies of their manifests from their receiving facilities to meet recordkeeping requirements. State inspectors and EPA inspectors can view manifests for all states through RCRAInfo. Scope of e-Manifest e-Manifest facilitates 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 implements e-Manifest regulations until 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) ------- How e-Manifest Impacts Inspectors Inspectors are 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 maintain 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. What All Inspectors Need to Do 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.aov/rcrainfoprod/action/secured/l ogin). 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 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 For more information on EPA's e-Manifest Program and frequently asked questions: Go to: http://www.epa.gov/e-manifest Access to Manifest Copies Did the entity sign electronically? iN° Yes Is the entity a receiving facility? No Is the entity a generator who is Yes using hybrid manifest? | No Is the entity a generator who is Yes registered for e-Manifest? No 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. U.S. Environmental Protection Agency EPA 530-F-20-016 ------- |