Baron Environmental Associates, L.L.C.
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776 Mountain Blvd, Watchung, NJ 07069

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Hazardous Waste e-Manifest Update

December 10, 2015

 

For over a decade, the Environmental Protection Agency (EPA), individual states, industry and related stakeholders have had a mutual interest in developing a national e-Manifest system.  The purpose of this program would be to facilitate the electronic transmission of the uniform manifest form and make the use of the uniform manifest much more cost-effective and convenient for users. On October 5, 2012, the Hazardous Waste Electronic Manifest Establishment Act went into law, authorizing the EPA to implement a national electronic manifest system.

 

Highlights of the Act:

 

•The “e-Manifest” will be developed and made available to all who manage hazardous waste.  The e-Manifest system will create an option for completing, signing and storing hazardous waste manifests electronically. 

•The Act authorizes the EPA to collect reasonable user fees for all system related costs including development and maintenance.

•The EPA must establish a System Advisory Board within 3 years after the Act is passed in order to advise the EPA on system performance and user fees.

•The Act requires that the e-Manifest Information Technology (IT) system must be up and running by October 5, 2015

•Requires that the EPA conduct annual Inspector General (IG) audits of the e-Manifest system and submit biennial reports to Congress

•The Act requires that EPA must establish a uniform effective date in all states for e-Manifest, and must implement e-Manifest until States are authorized to do so.

 

About the System:

 

The system will include:

•A standardized, secure, system-to-system interface to allow existing industry IT systems to communicate with the centralized e-Manifest system

•A web interface compatible with mobile devices (for industry users that do not have an existing IT solution or do not plan to integrate their existing system)

•Data sharing with the states via Exchange Network services

•A public interface allowing public data access

•Electronic signature procedure that adheres to CROMERR  (identity proofing of electronic signature)

 

Benefits:

•Reduction of the millions of paper manifests generated each year

•The e-Manifest system will give emergency responders more access regarding the types and sources of hazardous waste that are in transit between generator sites and waste management facilities

•The system will track the manifest throughout the shipment, capture data and report back to the system every time the manifest is signed by a new party (indicating a transfer of the waste), and provide a means of reporting the status of the shipment (draft, in transit, received, etc.

•Can be used as a tool for hazardous waste handlers to enhance recordkeeping compliance

 

Implementation:

•Waste handlers will have the option of continuing to use paper manifests or the e-Manifest system

•EPA will continue to collect user fees from waste handlers regardless of paper or electronic manifest use (example – NJDEP currently charges $11 per manifest for administrative fees).

 

 Schedule Moving Forward:

  • September 2015 – initial functionality completed

  • Winter 2016 – minimal viable product development

    • Begin receiving live data from TSDF’s

  • Spring through fall of 2016 – early full scale development

  • Fall of 2016 through winter of 2017 – rolling iterative releases/testing of system.

  • Spring of 2018 – national deployment (collecting user fees)

  • User fee regulatory development process completed (i.e. final rule) no later than 90 days prior to system online-deployment date

 

For more information, click here: Hazardous Waste Electronic Manifest System (“e - Manifest”) website
 

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