Step By Step Guide How To Use A Hazardous Waste Manifest: Everything You Need To Know

Hazardous Waste Tracking Manifest For 2025: Expert Solutions From Secure Waste

As of June 30, 2018, the Environmental Protection Agency (EPA) has instituted a crucial change in the management of hazardous waste by implementing digital tracking for hazardous waste manifest shipments across the United States.

This regulatory shift encompasses not only state-regulated dangerous waste but also encompasses federally-regulated waste under the Resource Conservation and Recovery Act (RCRA). Creating the EPA’s e-Manifest system modernizes and streamlines the manifest process, facilitating standardized hazardous waste manifests and consolidating critical tracking information into a single, easily accessible database.

This innovative program enhances safety and compliance, providing significant advantages for waste generators and treatment, storage, and disposal facilities (TSDFs).

In anticipation of future developments, the EPA’s third “Final Rule” concerning e-manifests will take effect in January 2025. This iteration will introduce various updates to the existing regulations. At Triumvirate Environmental, we actively monitor the EPA e-Manifest program updates, ensuring that our clients experience a smooth transition into these new regulations. 

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Secure Answers: What is e-Manifest?

“e-Manifest” refers to the advanced digital tracking system designed to manage hazardous waste shipments throughout the United States. This electronic framework applies not only to dangerous state-regulated and RCRA wastes but also to those governed by the Toxic Substances Control Act (TSCA), encompassing imported and exported waste materials.

The e-Manifest system meticulously tracks waste from the moment it departs the initial generator through each phase of transportation and concludes upon its arrival at the designated receiving facility, ensuring transparency and accountability throughout the process.

Who regulates/mandates e-Manifest? And Who Is Affected

The Environmental Protection Agency (EPA) regulates hazardous waste manifests across the United States, including implementing the e-Manifest system for digital tracking. This regulation is crucial for ensuring safety standards, compliance, and protecting the environment while handling hazardous waste.

Very Small Quantity Generators (VSQGs) and Polychlorinated Biphenyl (PCB) generators are exempt from registering for e-Manifest. All other hazardous waste generators, transporters, and receiving facilities must register.

As of January 22, 2025, large quantity generators (LQGs) and Small Quantity Generators (SQGs) will be required to register via the RCRAInfo system. The receiving facility must submit the electronic manifest to the e-manifest system and pay any associated fees.

Do You Understand RCRA Information?

RCRA Info is a national database the EPA manages that tracks information regarding hazardous waste handlers—including generators, transporters, and receiving facilities—and their waste management activities.

What Is The Required Information For Waste Manifests

To ensure proper management, a uniform hazardous waste manifest should contain detailed information about the waste, instructions for handling, signature lines for all relevant parties, and additional necessary details. Please look at the EPA’s website for a complete list of required information.

TimeLine For Implementation

The e-Manifest system took effect on June 30, 2018. Several updates under the final third rule will begin on January 22, 2025, with a significant regulatory deadline on December 1, 2025.

Registration Process And Submission for e-Manifest

To register for e-Manifest, facilities must create an account with RCRA Info using their EPA ID number.

Receiving facilities are required to submit an electronic manifest within 30 days of receiving it. It’s important to note that only receiving facilities are tasked with uploading manifests to the e-Manifest system; generators are not responsible.

What Is The Retention of Waste Manifests

Generators and transporters must keep electronic hazardous waste manifests for at least three years. Depending on specific circumstances, receiving facilities may need to maintain manifests longer.

Secure Waste Explains Waste Manifesting

Waste categorized as state-regulated hazardous waste, RCRA waste, and Toxic Substances Control Act (TSCA) must be manifested. Household hazardous wastes (HHWs) are typically exempt from this requirement.

What Is Un-Manifested Waste?

Un-manifested waste refers to hazardous waste generated that is not reported on a uniform hazardous waste manifest.

Across State Lines e-Manifest Regs

If federal or state laws require waste to be manifested, it falls under the e-Manifest regulations. This applies regardless of whether the waste needs to be manifested in the generator’s state, the receiving state, or both. Knowing the relevant state regulations concerning hazardous waste management in both the generating and receiving states is essential.

Signature of e-Manifests

Transporters, brokers, or receiving facilities can prepare and sign e-Manifests on behalf of the generator, provided they have been certified as preparers or certifiers by the generator’s site manager and possess the appropriate permissions along with the correct EPA ID number in RCRA Info.

The uniform hazardous waste manifest form is standardized across all 50 states; however, several aspects of its use may differ depending on state regulations. Key variations include:

• The number of manifest copies required and their distribution.
• The presence of state-listed hazardous wastes, substances classified as hazardous in state regulations but not necessarily recognized as such under federal laws.

In Maryland, specific requirements govern the distribution of manifest copies beyond federal regulations. These include:

• The destination facility, whether in Maryland or another state, must send a copy of the manifest to the Maryland Department of the Environment, Hazardous Waste Program.
• If a Maryland destination facility receives hazardous waste from an out-of-state generator, it must only submit a copy of the manifest to the generator’s state regulatory agency if that state mandates such a submission.
• Generators in Maryland are not required to send a copy of the manifest to the Maryland Department of the Environment.
• Maryland generators sending waste to facilities in other states should verify that state’s requirements to determine whether they need to submit a copy of the manifest to that state.

Awareness of these specifics is crucial for compliant waste management practices in Maryland.