Frequent Questions about e-Manifest
On this page:
- General
- Generators
- Receiving Facilities
- Manifest Preparation, Brokers
- Transporters
- Federal and State Implementation
- Fee Obligations
- Record Retention and Distribution
- Data Policy and Data Correction
- System-Specific Questions
- User Registration
- Invoices/Payments
- Polychlorinated Biphenyls (PCBs)
*EPA last updated these frequent questions on 3/26/2024. These frequent questions do not include information from the final Third Rule yet.
General
1. What is an electronic manifest?
An electronic manifest is the electronic format of the uniform hazardous waste manifest obtained and completed through the e-Manifest system. (Manifests obtained through registered printers are referred to as paper-based manifests.)
The manifest is used to track hazardous waste from the time it leaves the generator facility where the waste was generated until it reaches the designated receiving facility that will treat, store, or dispose of the hazardous waste.
Electronic manifests can also be updated, signed, corrected, and stored in the EPA’s e-Manifest system (also referred to as e-Manifest), which acts as the national repository and central hub for manifest data for use by EPA, states, and industry.
2. How can I access the e-Manifest system?
The e-Manifest system is a module component of the Resource Conservation and Recovery Act (RCRA) Information System (RCRAInfo), an IT system used by EPA, states, and industry to report and track RCRA regulated hazardous waste activity. To access your manifests through RCRAInfo, you’ll need the following:
- An EPA RCRA site identification number (EPA ID)
- This is a unique twelve-character alphanumeric assigned to a physical location (or transporter) that identifies a site where hazardous waste activity is conducted.
Learn more about obtaining an EPA ID.
- This is a unique twelve-character alphanumeric assigned to a physical location (or transporter) that identifies a site where hazardous waste activity is conducted.
- A RCRAInfo user account
- After you’ve obtained an EPA ID, register for a free account at https://rcrainfo.epa.gov. You’ll need to request access to your EPA ID, which will be approved by state regulators or an existing Site Manager if one is present.
Learn more about permission levels.
- After you’ve obtained an EPA ID, register for a free account at https://rcrainfo.epa.gov. You’ll need to request access to your EPA ID, which will be approved by state regulators or an existing Site Manager if one is present.
After the above pre-requisites have been met, you will be able to find all manifests associated with your EPA ID in RCRAInfo under the e-Manifest module.
3. Does the e-Manifest system collect paper manifests?
Yes, the e-Manifest system stores final copies of all manifests, both electronic and paper. Receiving facilities that receive waste that must be manifested under federal or state law must submit those manifests to EPA using one of the available submission options. Once submitted, states and industry can make corrections to their paper manifest data electronically in e-Manifest through the post-receipts corrections process; the system retains an auditable record of all such corrections.
4. Is the e-Manifest system free?
Users are not charged a fee for registering or using the e-Manifest system to create, update, sign, view, or correct their manifests. However, receiving facilities are responsible for paying a per manifest user fee that accrues when they submit the final signed manifest to EPA’s e-Manifest system. EPA sets user fees based on the costs of processing manifests and according to a formula in the RCRA regulations. EPA updates these user fees every two fiscal years.
5. Can I sign electronic manifests without registering?
Yes, there are a couple ways that field personnel, employees and contractors with direct physical responsibility for the waste shipment, can sign electronic manifests through a Remote Signer, a registered user in RCRAInfo with sufficient access to sign electronic manifest. The field personnel does not need to be registered in either scenario:
- The field personnel can communicate with another employee (a Remote Signer) who is registered and can execute the electronic signature in the e-Manifest system.
- Field personnel may use their site’s waste management software to execute electronic signatures through system-to-system communication with the e-Manifest system. In this instance, the Remote Signer is the individual who’s credentials are used for system-to-system communication.
Either method requires that the site seeking to sign an electronic manifest must have a registered user in RCRAInfo prior to the shipment. For additional information, see the Remote Signer Policy.
6. What documents besides the manifest form and continuation sheets are collected by EPA? What about land disposal restriction (LDR) notices?
The e-Manifest system currently focuses only on manifests and continuation sheets involving the shipment of wastes that require a manifest under federal law (federal RCRA or regulated polychlorinated biphenyl waste) as well as the manifests and continuation sheets involving state-only regulated wastes subject to manifest requirements under state law. We do not process LDR notices or any other non-manifest documents. We also do not process export manifests at this time. EPA recycles any miscellaneous documents it receives.
7. What is a hybrid manifest?
The hybrid or mixed paper/electronic manifest is a specific manifest approach that EPA adopted to assist generators who are not able to fully participate in electronic manifesting at the time of system launch. The hybrid manifest allows transporters to initiate an electronic manifest in e-Manifest and use this manifest with their non-participating generator customers. The initial transporter may print a copy of the electronic manifest for the generator, and the generator may sign the paper copy, obtain the initial transporter's ink signature on this paper copy, and then retain this paper copy on-site as the generator's initial manifest copy as is done under traditional manifest requirements. Thereafter, the initial transporter and subsequent waste handlers complete the remainder of the tracking of the shipment electronically in e-Manifest with electronic signatures and electronic transmissions to the system. Hybrid manifests are charged the same fee as a fully electronic manifest. Generators that utilize hybrid manifest are also given paper copies of completed manifests from receiving facilities.
8. Does the e-Manifest system collect manifests for wastes that are not regulated as hazardous by EPA, but that are regulated as hazardous by a state?
Yes, the e-Manifest system collects manifests for wastes shipped on a manifest, where the manifest is required either by federal law, or the law of the generator state or destination state. Users who use the manifest voluntarily for their waste shipments (i.e., the manifest is not required by federal or state law) are not required to submit their manifests to the e-Manifest system.
9. What manifests are required to be submitted to EPA? If someone chooses to use the EPA manifest form, but isn’t required to do so, must that form be submitted to EPA?
Generally, if the wastes listed on a manifest are not required by federal or state law to be shipped under a manifest, then there is no requirement that such manifests be submitted to EPA. However, please refer to the “Receiving Facilities” section for further explanation of manifest requirements when a generator relies on waste determinations from the receiving facility.
10. How does e-Manifest apply for wastes that are required to be manifested in one state (e.g., the state where the waste was generated) but not required in another state (e.g., the state where the waste was received)?
If either the generation state or receiving state requires a manifest during the movement of the waste shipment, then the receiving facility must submit the manifest to the system and pay any applicable fees associated with that manifest. If the generation state requires a manifest, the receiving facility must submit this manifest to e-Manifest, even in instances where the waste is not regulated in the destination state and does not legally require a manifest under the laws of that state. This enables the origination state to confirm the proper receipt of its regulated wastes, even when those wastes are shipped out-of-state for management.
11. What about states that require a manifest when the shipment moves through the state?
The e-Manifest Act provision on interstate shipments applies only in cases where either the origination state requires a manifest, or, the state in which the waste will be transported to a receiving facility for management (i.e., destination state) requires a manifest. Transit-only states, that is, states through which waste is transported en route to a designated facility in another state, are not covered by this provision, so their tracking requirements would not trigger any responsibility for the designated facility to respond to a transit state’s manifest requirement.
12. Are imported wastes shipped on a manifest included in e-Manifest? Does it include exported waste shipped on a manifest?
The e-Manifest system tracks import manifests, as these manifests begin with a U.S. importer, and end with a U.S. receiving facility. Thus, once these hazardous wastes enter the United States, their tracking is not that different than any other domestic waste shipment.
Currently, the e-Manifest system’s submission and fee collection requirements are focused on the receiving facilities in the United States that are clearly within the jurisdiction of our manifest regulations. Export manifests track wastes that are received at foreign consignees, and EPA lacks jurisdiction to require these foreign facilities to submit manifests to e-Manifest and pay user fees to EPA. Therefore, the e-Manifest system does not currently track export manifests. EPA is currently considering regulatory changes to address whether exporters or other entities involved with export shipments should supply these export manifests to the system and pay the requisite processing fee. EPA will address these changes in an upcoming rule, but until further notice, the system will not collect export manifests.
13. How do the e-Manifest requirements apply to VSQGs who ship their hazardous waste to a LQG for consolidation?
In the Generator Improvements Rule, EPA promulgated a regulation to allow VSQGs to ship their hazardous waste off-site to an LQG for consolidation if the VSQG and the LQG are under the control of the same person, and the VSQG complies with specific conditions for marking its containers. Under the federal rules, if a VSQG meets the conditions for shipment to LQGs under control of the same person, the shipments to the LQG are not required to use a RCRA manifest to track these shipments. Shipments of waste not subject to the manifest under either federal or state law are not subject to e-Manifest requirements.
Note that states authorized for the RCRA program must adopt the provision allowing consolidation of VSQG waste at an LQG before entities within that state can start operating under the provision. In addition states can be more stringent in their regulations. For site-specific questions, please contact your authorized state.
14. How does e-Manifest apply to rail shipments?
Current regulations require the rail company receiving hazardous waste for transport to sign the manifest at the rail company office and then forward the manifest copies to the next non-rail transporter or to the receiving facility. Rail companies that receive electronic manifests are able to designate a company official to register with e-Manifest and to sign manifests received at the rail company electronically rather than with ink signatures. Also, the signed manifests may then be forwarded electronically by e-Manifest to the next non-rail transporter or the receiving facility.
15. When a shipment involves multiple rail transporters, what are the procedures for identifying the transporters on the manifest and obtaining rail transporter signatures?
Transportation of hazardous waste by rail involves special manifest procedures. Under Title 40 of the Code of Federal Regulations (CFR) sections 262.23(d) and 263.20(f) (and equivalent authorized state regulations), only the initial rail transporter must be listed in the transporter fields of the manifest. The initial rail transporter must sign and date the manifest (typically from the rail company’s office) to acknowledge accepting the waste for transportation in the rail system and then return a signed copy to the generator or non-rail transporter from which it accepted the waste. The remaining copies of the manifest are then forwarded to the next non-rail transporter or to the designated facility for further manifest tracking after the waste shipment leaves the rail system. Thus, when there are multiple rail transporters involved with the transport of hazardous wastes, the manifest only tracks delivery to the first rail transporter, and there is no identification on the manifest of the subsequent rail transporters nor collection of signatures from them when they take custody of the hazardous wastes within the rail system.
16. Have the data elements applicable to paper manifests changed with the use of electronic manifests?
No, the basic regulations and instructions for completing an electronic manifest are not materially different from regulations or instructions for completing a paper manifest. The data elements remain the same; the only differences involve completing an electronic form and signing the form electronically. EPA determined in the 2014 One Year Rule that electronic manifests that are obtained from e-Manifest, used in accordance with the e-Manifest regulations, and submitted to the e-Manifest system are the legal equivalent to paper manifests for all RCRA purposes.
17. Are "milk-run" or "consolidated waste" manifests subject to e-Manifest's submission and fee requirements?
No. Receiving facilities need only submit manifests that apply to waste shipments for which the RCRA manifest is required under either federal or state law. “Milk run” or “consolidated waste” manifests are separate tracking documents required by states for certain state-only regulated wastes. These “milk run” manifests typically involve consolidating waste shipments from multiple generators on one manifest document, a practice that is not supported by the RCRA manifest. The user should follow state law requirements on the disposition of these manifests.
18. Are Very Small Quantity Generator (VSQG)/Conditionally Exempt Small Quantity Generator (CESQG) waste shipments subject to e-Manifest?
This answer depends on the state and if the waste contains PCBs subject to the manifesting regulations and policies per title 40 CFR part 761. In general, VSQG/CESQG waste are exempt federally from the RCRA manifest, provided the regulatory conditions for the exemptions are met. Where these exemptions are applicable (i.e., in unauthorized states and in authorized states that have adopted these manifest exemptions), these wastes are exempt from manifest requirements and therefore are not subject to e-Manifest.
However, in some authorized states, the states have elected to require manifests for VSQG/CESQG waste shipments. In such cases, the manifests required by the states to track these shipments are subject to e-Manifest.
With regards to PCB shipments, unless specifically exempted from the requirements in 40 CFR part 761 subpart K, the PCB regulations require generators to prepare a manifest on EPA Form 8700-22, and, if necessary, a continuation sheet prior to transporting regulated PCB waste. Regulated PCB waste(s) means those PCBs and PCB Items that are subject to the disposal requirements of 40 CFR part 761 subpart D. Refer to 40 CFR section 761.207 for more information.
Additionally, the federal rules addressing VSQGs require manifests for certain episodic waste events at VSQGs. When such an episodic event occurs, and the VSQG rules apply, then these shipments and their manifests would be subject to e-Manifest.
19. Are Household Hazardous Waste (HHW) shipments subject to e-Manifest?
Generally, Household Hazardous Wastes (HHWs) are exempt federally from the RCRA manifest, when the regulatory conditions for the HHW exemption are met. In those cases where the HHW exemption applies and the regulatory conditions are met, these HHW shipments are exempt from manifest requirements and are therefore not subject to e-Manifest.
However, in some authorized states, the states have elected to require manifests for some HHW shipments (e.g., shipments that occur after HHW has been collected from HHW collection programs). In such cases, the manifests required by the states to track such HHW shipments are subject to e-Manifest.
20. Are wastes managed under the RCRA precious metals exemption subject to e-Manifest submission and fee requirements?
Yes. Wastes that are subject to the RCRA precious metals exemption are required to use a RCRA manifest, thus, the receiving facility must submit these manifests to EPA and pay the applicable user fee.
21. Are low-level mixed waste shipments subject to e-Manifest?
No. Low-level mixed radioactive/hazardous wastes are subject to a conditional exemption from the definition of hazardous waste that is codified at 40 CFR part 266, subpart N. Among these Subpart N provisions is a conditional exemption at 40 CFR section 266.305 et seq. that applies to the transportation and disposal of these wastes. These low-level mixed wastes are exempt from RCRA transportation requirements, including the RCRA manifest, when they are shipped for disposal to designated low-level radioactive waste disposal facilities (LLRWDFs) under the conditions of the exemption. These conditions include the use of the NRC’s Uniform Low-Level Radioactive Waste Manifest for tracking the transportation of these wastes. Since these low-level mixed waste shipments are subject to the NRC’s manifest, and not the RCRA manifest, these waste shipments are not subject to e-Manifest. Those involved in the transportation and receipt of these radioactive wastes should not submit the NRC manifest to e-Manifest.
Generators
1. Do generators have to register for e-Manifest?
It is not required that generators register for e-Manifest. Generators who are not registered in e-Manifest can continue to use paper manifests, as they do under the existing paper-based manifest system, or under the hybrid manifest scenario.
However, generators need to register at least one user if they wish to sign electronic manifests, view and maintain manifest records in the system, or submit post-receipt data corrections.
2. How do generators, who are not registered in e-Manifest, receive a copy of the completed manifest? Are receiving facilities responsible for sending a copy to the generator in this case?
Generators that do not establish accounts for viewing their manifests should make arrangements with their receiving facilities to supply the generators with paper copies of completed manifests. The e-Manifest system only supplies electronic copies of completed manifests to generators.
3. Does the generator have to submit the generator copy of the manifest to EPA?
No, generators do not have to submit paper manifests to EPA. EPA only collects paper manifests from the receiving facility.
4. What happens if a generator is ready to sign manifests electronically in EPA's e-Manifest system, but the transporter or receiving facility is not set up to sign electronically?
For a generator to sign electronic manifests in e-Manifest, all other entities in the chain must also be able to sign electronically in e-Manifest. If the transporter or receiving facility is unable to sign electronically, the generator must use a paper manifest.
5. Can a generator without electronic signature capability still participate with an electronic manifest?
Yes. An electronic manifest can be executed in one of two ways with generators that lack the capability to electronically sign. First, if there is an offeror (typically, the initial transporter) who has prepared the waste shipment and the manifest, and has sufficient knowledge of the shipment’s preparation to be able to certify to the facts in the generator/offeror certification statement, then the offeror preparing the shipment can sign the manifest electronically on behalf of the generator. Second, a generator without electronic signature capability can take advantage of the hybrid process, which allows the generator to obtain, sign by hand, and retain a paper printout of an electronic manifest that all subsequent handlers sign and complete electronically.
Handlers can determine in RCRAInfo if a generator can electronically sign. When adding a site’s EPA ID to the electronic manifest, the system will return Yes/No if there is a user associated with a site who can use Quick Sign or a user who can e-Sign the official manifest copy of record (i.e., CROMERR-compliant signature).
6. Can generators use the e-Manifest system to keep records of their manifests?
Yes. Generators that have registered with e-Manifest may elect to use their e-Manifest account to store and retrieve their manifest copies.
For paper manifest users, the image file of the final manifest copy signed by the receiving facility is uploaded to e-Manifest, and copies of these final manifest image files will be available for registered generators to view and retrieve. Under the federal manifest regulations, the generator’s initial paper copy may be discarded and replaced by the final manifest copy in e-Manifest to meet their recordkeeping requirements once the image file of the final manifest is available in their account.
Note, however, that this policy (discarding the initial paper copy) does not apply to generators that use the hybrid manifest. Such generators must retain their initial paper copy among their records for the entire 3-year record retention period, since this initial, paper copy is the only copy of the manifest that includes the generator’s signature on the generator/offeror certification. Also, generators should take into consideration any additional reporting requirements relevant to their state before discarding the initial copy, such as sending the generator initial copy directly to the state.
7. Can generators use e-Manifest for RCRA inspections?
Yes. Generators that are registered and maintain access to e-Manifest can use the records stored in e-Manifest to satisfy the manifest recordkeeping requirements. These generators can also print hard copies of their manifests from the system at the request of a federal or state inspector. Federal or state inspectors can also use e-Manifest to perform manifest reviews prior to conducting an on-site inspection, and obtain copies of the manifests prior, and subsequent, to the inspection.
8. Is there an explicit regulatory requirement that generators are monitoring their manifests in the system and verifying the receipt of their wastes by receiving facilities?
Under the manifest regulations, there is an explicit requirement that generators conduct exception reporting, and this requires the generators to monitor their electronic and paper manifests to verify that all their waste shipments are received in a timely manner by the facility designated on their manifests. With both paper and electronic manifests, the generator is obliged to inquire of transporters and receiving facilities when their final manifest copies appear overdue, and to report exceptions to state or Regional officials when these shipment exceptions cannot be reconciled within regulatory time frames.
9. How does e-Manifest affect Exception Reporting by generators?
Exception reporting requirements (40 CFR section 262.42) remain unchanged by e-Manifest. This includes the time frames for follow-up actions by generators when a manifest signed by the receiving facility is not timely received by the generator. Exception reporting requirements, therefore, continue to apply equally to paper and electronic manifests.
The first follow-up action for generators in section 262.42 is to inquire of the transporter or designated facility on the status of its waste, if a signed copy of the manifest has not been received by the generator within 35 days of the date the waste was accepted by the initial transporter. If the status is not resolved by day 45, then the generator must file a written exception report with the regulatory agency. (A distinct process is specified for small quantity generators).
When electronic manifests are widely adopted, the generators’ ability to confirm receipts by the receiving facility will be much more immediate than with paper manifests. However, with paper manifests, receiving facilities have up to 30 days from delivery to submit its final copy to e-Manifest. After being received by EPA, paper manifests (e.g. scanned image upload, data plus image upload) need additional time to be processed and entered into the system.
EPA plans to further explore whether there should be changes to the Exception Reporting process on account of e-Manifest.
10. Must I get an EPA ID Number for emergency response, remediation sites, or other transitory generation sites?
Yes. The RCRA regulations generally require that generators must not transport or offer hazardous waste for off-site transport unless the generator has obtained an EPA Identification Number. Further, the transporter requirements state that a transporter must not transport hazardous waste without having received an EPA Identification Number.
The RCRA Subtitle C regulations generally do not distinguish between sites at which hazardous waste is generated on an ongoing basis versus waste generated from a single event. Thus, on-scene coordinators, other generators, or transporters responding to emergency response sites, remediation sites, or spill/discharge events must typically submit the EPA Site ID Form (Form 8700-12) to their EPA Region or authorized state agency to obtain an EPA ID Number, or where appropriate, request from their regulator a provisional or emergency ID Number.
Provisional or temporary ID Numbers are issued to sites that are not sites of ongoing industrial processes, but are instead remediation sites or sites involved with “one-time” generation events. Provisional ID Numbers are issued after submission of the Site ID Form, but they may be of limited duration. Emergency ID Numbers are for those spill or discharge events where the generation of waste is unforeseen and short-term. One responding to such an emergency typically would not need to submit a complete Site ID Form to obtain an Emergency ID Number, but could instead provide provisional details over the phone about the incident and obtain an Emergency ID Number for use on its manifests.
In addition, EPA has implemented in RCRAInfo a means for states to opt into a process for the immediate, electronic issuance of ID Numbers in response to emergencies. Where states opt into this electronic process, users needing ID Numbers in the face of emergency circumstances will have another, expedited means for obtaining an ID that will not necessitate even a phone call to their regulator.
An existing federal transporter regulation (40 CFR section 263.30(b)) provides authority for EPA or state officials to waive manifest preparation requirements and the requirement to use transporters with EPA ID Numbers to respond to certain discharge events during transportation for which it is determined by the government official that the immediate removal of the waste is necessary to protect human health and the environment. This authority is seldom used however, because the more common practice in such cases is to instead promptly issue provisional or emergency ID numbers for these sites and events, rather than waivers. Nevertheless, in exceptional cases where time is of the essence, and an immediate response to a spill or other emergency is necessary to protect human health or the environment, existing EPA policy provides that officials may waive the EPA Identification Number requirements for the generators and transporters that are engaged in immediate hazardous waste removal in response to a discharge or other emergency incident. Refer to Program Implementation Guidance on Issuance of Provisional EPA I.D. Numbers, RCRA Online # RO 12016, November 26, 1980. Such waivers should be reserved for those emergency events for which it would not be reasonable to defer the response action until an ID Number is issued.
Otherwise, when an EPA ID Number, or provisional or emergency ID Number is obtained for the affected site, the person responsible as generator or offeror for off-site shipments from the remediation, discharge or other transitory site must use the ID Number issued to it in completing its paper or electronic manifests.
If the response action is an emergency removal action for which a waiver of the ID number requirement has been granted, then in these circumstances, the paper manifest should be used, with the Generator ID Number field left blank, and a statement in Item 14 explaining that an ID Number waiver was granted because of the emergency, and a brief description of the emergency event justifying the waiver.
11. Are temporary or provisional facilities without EPA IDs subject to e-Manifest?
If a manifest is required for shipments from these facilities under federal or state law, then these facilities are subject to e-Manifest. However, without an EPA ID the temporary site will only be able to complete hybrid manifests (or continue to use paper), as an EPA ID number is required for fully electronic manifests. If it is desired to use fully electronic manifests, then these sites must obtain an EPA ID before completing any electronic manifests by filing EPA Form 8700-12 with the EPA Region or authorized state or requesting one through the myRCRAid module in RCRAInfo.
12. Do generators need to keep a paper copy of the manifest onsite for DOT inspectors?
No. Copies of manifests in e-Manifest satisfy the DOT’s hazardous materials regulations on retention of shipping paper records, although they may be asked to print a hard copy from e-Manifest at the request of the inspector. This is also a requirement for RCRA inspectors.
13. Do VSQGs need an EPA ID Number?
VSQGs in unauthorized states or in authorized states that have adopted the VSQG (formerly CESQG) exemption are generally exempt from manifest requirements, if they meet the conditions of the exemption. In these circumstances, the exempt VSQG or CESQG would not need to participate in e-Manifest and would not need an EPA ID Number. However, if an exempt VSQG or CESQG has secured an EPA ID number, it should be used on all manifests.
However, in some authorized states, the states have elected to require manifests for VSQG/CESQG wastes. Additionally, federal rules require manifests for certain VSQG episodic waste events, and in these cases, the VSQG must also obtain an EPA ID Number by submitting EPA Form 8700-12.
In summary, e-Manifest applies wherever there is a requirement under either state or federal law to use the RCRA manifest for a VSQG/CESQG waste shipment.
In those circumstances where e-Manifest applies to VSQG/CESQG shipments (other than for episodic event shipments), an EPA ID Number is not required if the VSQG/CESQG uses a paper manifest to track its waste. In such cases, the VSQG/CESQG generator could complete its paper manifest by supplying all the other information required on the manifest form to identify the generator. However, EPA encourages the use of electronic manifests, and if such a generator desires to complete an electronic manifest (or is required to use the manifest to track an episodic event shipment), then it must have an EPA ID Number. A VSQG/CESQG lacking an EPA ID Number should file the Site ID Form and obtain an EPA ID Number specific to their site if it plans to use the electronic manifest. (If a VSQG/CESQG has a unique state-issued ID, please contact your state on whether this could be transferred to EPA for use for electronic manifesting.)
14. How many waste codes must be entered on electronic manifests?
The regulatory requirements for entering waste codes are not different from paper, but as a practical matter, electronic manifests offer users more flexibility in entering federal and state waste codes.
The regulations still provide that the generator or offeror must enter on the manifest the federal and state waste codes that best represent the waste and its hazards. Where there are multiple codes that apply to a waste, the regulations provide that up to six federal and state codes can be entered on the form, and the paper form provides six data fields per waste for this purpose.
Electronic manifests, however, are not limited by the physical space constraints that limit paper form users to entering at most six codes. While entering six waste codes per waste for electronic manifests will suffice for regulatory compliance, users of electronic manifests may enter more than six waste codes, if so desired.
15. What is required on the manifest for shipment of non-creditable hazardous waste pharmaceuticals?
For more information refer to: Frequent Questions about Manifesting Non-creditable Hazardous Waste Pharmaceuticals.
Receiving Facilities
1. What options do hazardous waste handlers have for submitting manifests to the e-Manifest system?
Receiving facilities have three options for submitting their manifests to EPA. First, for electronic manifests, the receiving facility copy is submitted immediately to e-Manifest when signed electronically by the receiving facility. This is the most efficient method of submitting manifests to e-Manifest, and because it is an automated process, results in the lowest user fee.
Since users retain the option of using paper manifests to track their waste shipments, the e-Manifest system provides receiving facilities with two options for submitting the final receiving facility copy to e-Manifest. First, receiving facilities may upload a scanned image of the top copy of the manifest to be processed by the system’s paper processing center. Second, receiving facilities may submit paper manifests by uploading to the system both a data file and an attached image file copy of the form. The second option results in a lower paper processing fee, because the upload of the data file eliminates much of the manual processing that produces higher costs for the scanned image only submission method.
2. How soon after receiving a shipment do I need to electronically sign for the shipment?
Under the manifest system's chain of custody, a waste handler is presumed to retain custody and responsibility for hazardous wastes in transportation until that handler obtains the signature of the next handler. So, a transporter will ordinarily expect the receiving facility to sign the manifest when the transporter delivers the waste to the receiving facility and will want to obtain this signature before it leaves the facility. This requirement is the same for paper and electronic manifests.
3. How soon after receiving a manifest do I need to submit that manifest to EPA?
The regulations for paper manifest submissions specify that a completed paper manifest must be submitted to the EPA’s e-Manifest system within 30 days of the delivery of the waste to the receiving facility. Electronic manifests, of course, are created, transmitted, and signed in the e-Manifest system.
EPA notes that manifests typically are completed once the receiving facility signs and dates the manifest acknowledging receipt of the waste to the facility. However, a receiving facility may reject a waste shipment immediately in full and use the original manifest to forward or return the waste shipment to an alternate facility or generator, respectively, provided certain conditions are met. In such cases, the receiving facility must sign and date the original manifest. However, the manifest is not completed by the execution of the signature and should not be submitted to the e-Manifest system at that time.
When a facility immediately rejects a full waste shipment and directs the transporter to forward the rejected waste to an alternate facility or back to the generator by completing the Alternate Facility/Generator item on the original manifest (Item 18c), the original transportation of the waste shipment has not ended. Rather, transportation of the fully rejected shipment ends when the alternate facility or generator takes custody of the shipment from the delivering transporter. At that time, the alternate facility or generator completes the original manifest by signing and dating the manifest acknowledging receipt of the fully rejected waste shipment from the delivering transporter.
An alternate facility must submit the completed, original manifest to the e-Manifest system within 30 days of delivery of the waste to the facility. The generator must return the completed, original manifest to the rejecting facility that returned the shipment to the generator within 30 days of receipt of the rejected shipment. The rejecting facility must submit the completed, original manifest to the e-Manifest system within 30 days of receipt of the manifest from the generator.
4. Can a receiving facility sign for a transporter?
No. The "on behalf of" signature authorities only apply in limited instances to generator signature requirements. The manifest regulations require the transporter company's representative to sign the manifest to acknowledge receipt of the materials from the generator and to indicate the beginning of the transport of the waste. This is a different acknowledgment than the receiving facility's certification of receipt of the waste.
5. How can receiving facilities supply generators with the required final copies of their paper manifest?
There is a RCRA regulatory requirement that receiving facilities return a signed copy of the final manifest to the generator within 30 days of receipt of the waste. If the generator is registered with e-Manifest and uses its e-Manifest account for recordkeeping, then the image file produced from the receiving facility’s final manifest copy is delivered to the generator’s e-Manifest account when the image file is uploaded by the receiving facility or produced by the system’s paper processing center during the processing of scanned image uploads.
Alternatively, the receiving facility may satisfy this requirement by sending the copy in the mail, as has been the practice for many years.
Receiving facilities are responsible for determining whether their generator customers are registered with e-Manifest and using the system for monitoring their manifest records. Receiving facilities can use e-Manifest to make this determination: when a valid EPA ID is entered into the system, there is a Yes/No flag showing whether or not a site has a registered e-Manifest user.
Receiving facilities should continue to mail any paper copies to their generator customers, until they have confirmed that the generator is registered and using e-Manifest for recordkeeping.
6. Can I sign off (certify receipts) on a manifest with a bulk waste discrepancy of less than 10%? Does this manifest require a correction?
The e-Manifest requirements, including the post-receipt data corrections process, do not alter the existing discrepancy reporting requirements that have been in place for many years with respect to bulk shipments. In other words, for bulk wastes, there is not a “significant discrepancy” requiring follow-up and reporting if the receiving facility finds that the quantity it measures as received is within 10% of the quantity that was entered as the quantity shipped by the generator or offeror. The receiving facility may in such instances sign the manifest and certify to the quantities shown on the manifest, and this manifest does not require a correction. However, a correction may be advisable to ensure greater accuracy and precision with respect to manifest data reporting. The e-Manifest system is being developed to place a greater emphasis on accuracy in reporting quantities shipped and received, and as e-Manifest integrates in the future with the RCRA biennial report, data corrections may be necessary if the accuracy of manifest data is to be assured.
7. How should a state-only regulated waste facility that does not manage RCRA hazardous waste complete the Site ID Form to request an EPA ID Number?
Non-hazardous waste facilities that need an EPA ID Number for e-Manifest compliance must complete certain portions of the RCRA Site ID Form (Form 8700-12) to obtain an EPA ID Number. The facility should complete Items 1 through 10 of the Form and should check the first box under Item 1 to indicate that “Reason for Submittal” is to obtain an EPA ID number for an on-going regulated activity that will continue for a period of time.
The completion of Item 10 of the Site ID Form (Type of Regulated Waste Activity) requires special attention. The facility completing the Site ID Form must indicate a generator status under Item 10.A.1 for the Form to be accepted, so a facility that is not a generator must check “No” under Item 10.A.1 to proceed with their request.
The other waste activity indicators (Items 10.A.2 thru 10.A.7) can be left blank or can all be checked “No” if the facility is not involved in any of the waste activities described in the fields.
The state-only regulated waste facility should then enter in Item 10.C any applicable waste codes for the state-regulated wastes that are handled at their site and will be tracked under the manifests received at the facility. Since Item 10.C is reserved for the entry of state regulated (non-Federal) hazardous wastes, the facility should enter these codes regardless whether the state agency regulating these wastes defines them as state hazardous wastes, industrial waste, used oil, special wastes, or under another description. If the wastes involved are state-regulated and state law requires the RCRA manifest for their tracking, then the applicable state waste codes should be entered.
The final items of the Site ID Form to be completed by a non-hazardous or state-only regulated waste facility are comments under Item 18 and the Certification in Item 19. The comments section should include a comment that the facility is requesting an EPA ID Number as a non-hazardous waste facility for purposes of compliance with the e-Manifest Act.
8. Is submission of the Site ID Form sufficient to cause a facility and its ID Number to appear in the system’s look-up tables?
No. While the submission of the Site ID Form completed will result in the issuance of an EPA ID Number to the facility, this alone will not cause the facility and its ID Number to appear in the look-up tables that will be used for completing electronic manifests in e-Manifest. For this to occur, the facility must request that the state agency issuing the ID Number manually add the facility and its newly issued ID Number to the RCRAInfo e-Manifest Receivers List. Once that is done, persons completing electronic manifests will be able to select the facility from the receiving facility look-up tables.
9. If a generator initiates its shipment under a manifest and relies on the receiving facility to determine whether the waste is hazardous or not on receipt does the receiving facility need to submit the manifest to the e-Manifest system if it determines the waste shipment is not a federal or a state-regulated hazardous waste?
Yes. At the point of generation, the generator completed a manifest for the off-site shipment, because based on the generator’s process knowledge, the waste could likely be a hazardous waste. Although the waste is being shipped to a facility that will test the material and determine conclusively whether the material is a hazardous waste under federal or state law, the test result will not be available in time to affect the generator’s determination at the point of generation. In such cases, it is necessary to manage the material as a regulated hazardous waste and ship it off-site accordingly with a manifest. The manifest was thus required for this shipment, based on the generator’s process knowledge at the point of generation. The fact that the receiving facility could test the materials and determine at receipt that the material was not in fact regulated does not retroactively cancel the manifest or alter the fact that it was required when shipped off-site by the generator. Since any manifest that is required for off-site transportation under federal or state law must be submitted to the e-Manifest system by the receiving facility, the facility cannot decline to submit it to the system because of information it acquired post-receipt.
10. Can authorized states still require that a Discrepancy Report letter be sent to the states?
Yes. The e-Manifest system does not currently have the functionality to conduct discrepancy reporting, and the manifest regulations still provide that in the event of a significant discrepancy that is not reconciled within 15 days of receipt by the facility, the facility must send to the EPA Region or authorized state a discrepancy report letter and a copy of the paper manifest at issue. While the launch of e-Manifest resulted in the issuance of new e-Manifest requirements that EPA is now implementing, the authorized states remain authorized for the discrepancy report requirements. Therefore, the states retain their authority to receive the written discrepancy reports arising from the use of paper manifests, and those reports should be submitted to authorized states, and not to EPA.
11. If a facility returns rejected wastes or a regulated container residue to the entity named as the generator on the original manifest, but the generator named on the original manifest is in fact a treatment, storage, or disposal facility (TSDF), which party is responsible for the payment of the fee for the return manifest?
In the User Fee Rule, EPA provided that in the case of rejected wastes (or residues) that are returned to the generator named on the original manifest, the rejecting facility, and not the generator, is responsible for submitting the return manifest and the payment of the fee for the return shipment manifest. This requirement is determined by the specific manifest transaction at hand -- i.e., in this instance, a rejected waste or residue is being sent by the original TSDF back to the generator client named on the original manifest. The fact that this particular generator happens to be a TSDF and thus could be registered in the system already for user fee purposes is not relevant for this particular billing question. The rejecting facility is responsible for the submission and payment regardless of the generator’s status as a TSDF.
12. When hazardous waste is rejected, should a new manifest be used for the return shipment? In what box should the generator sign on the rejected manifest?
The hazardous waste rejection regulations for full, immediate rejections of shipments while the transporter is still on site require generators to sign Item 18c of the manifest. If the shipment is rejected in part or after the transporter has left the receiving facility, it requires a new manifest on which the generator would sign Item 20.
13. When rejected hazardous wastes are returned to generators on a manifest, what, if any, management method code should be entered on that manifest? Also, is a management method code required for regulated residue shipments that are returned to the generator?
On a rejected shipment, the generator must complete Item 19 because Item 19 is customarily completed by the receiving facility. The manifest regulations grant generators a 90-day or 180-day accumulation period to make new arrangements with a hauler to transport the waste off-site and arrange an alternate facility to receive the shipment (refer to accumulation time limits and other generator requirements at Hazardous Waste Generator Regulatory Summary). The rejection regulations also provide that generators receiving returned shipments must accumulate the returned waste on-site in accordance with the provisions of 40 CFR section 262.16 (small quantity generators) or 40 CFR section 262.17 (large quantity generators), depending on the amount of hazardous waste on-site in that calendar month. Therefore, generators must enter management method code H141 for storage.
Residue shipments that are returned to a generator also require a management method code, specifically, H141 for storage, in Item 19.
Manifest Preparation, Brokers
1. What methods of manifest preparation are supported in e-Manifest?
The e-Manifest system supports the preparation of manifests in three distinct ways. First, since manifest users still have the option of using paper manifests, those users preparing manifests for tracking waste shipments may continue to obtain paper manifests from any of the registered manifest printers approved by EPA, and complete, physically carry, and use them in the conventional manner. These paper manifests accompany the waste shipments, be signed by hand by waste handlers with changes in custody of the waste shipment, and then be submitted to the system by the receiving facility within 30 days of receipt.
Second, electronic manifests may be obtained from the system, and then prepared, signed, and transmitted electronically through e-Manifest as electronic manifests. The process under this second option is fully electronic from start to finish, with the electronic manifests being prepared and signed using portable devices rather than as a set of paper forms that are carried with waste shipments.
As a third supported method of manifest preparation, the system supports the hybrid, or mixed paper/electronic manifest. With the hybrid manifest, the manifest is obtained from the system and prepared by the preparer as an electronic manifest. However, when the initial transporter arrives at the generator site, the transporter presents the generator with a printed copy of the electronic manifest, and both the generator and initial transporter sign this paper copy by hand so that the generator can retain this one paper copy on-site as the generator's initial manifest copy. Thereafter, the hybrid manifest is processed by the transporter, subsequent waste handlers, and the e-Manifest system as an electronic manifest.
2. Can a transporter, broker, or receiving facility prepare and sign manifests ‘on behalf of’ the generator?
While any waste handler and broker can prepare a manifest "on behalf of" a generator, the authority to sign manifests is more limited. Manifests prepared by others for a generator customer can be signed by the generator, or by the agent (e.g. a contractor) of the generator operating on-site and performing generator responsibilities at the site for the generator, or by an offeror. An offeror is a person, typically the representative of the initial transporter, who performs the pre-transportation functions (e.g., packaging waste in containers, preparing and affixing labels, preparing the manifest) on-site, and has personal knowledge of the facts involved with the preparation of the waste for transportation. In these cases, an offeror can sign the generator/offeror certification on the manifest on behalf of the generator, because the offeror can certify that the waste materials have been properly described and the shipment is in proper condition for transportation.
3. I’m a broker. What will e-Manifest allow me to do and how do I register?
A broker may prepare manifests in e-Manifest for its generator clients. Because a broker may service multiple clients, EPA requires that brokers obtain an EPA ID Number using the Site ID Form (EPA Form 8700-12), so that we may track the manifest activities of brokers in e-Manifest, and make draft manifests available to brokers for the use of their clients. However, a broker may not sign manifests in e-Manifest on behalf of generator clients, unless the broker is operating at the generator site and can sign the manifest as an offeror of the waste shipment.
Transporters
1. Does the transporter need to register individual drivers in order to sign electronically?
No. As of February 10, 2023, EPA allows a Remote Signer, who is a registered user with sufficient permissions in e-Manifest to sign electronic manifests, to execute electronic signatures for contractors and employees of the same transporter who may not be registered or have network access at the time of shipment.
This policy is applicable to generators and designated receiving facilities as well. You can read the Remote Signer policy on RCRA Online.
2. Can a transporter’s electronic signature be executed by a person other than the individual with first-hand knowledge of the shipment?
Yes. As of February 10, 2023, transporters can contact a remotely located individual, with sufficient permissions in e-Manifest to sign electronic manifest for their site, to execute the electronic signature on their behalf. Remote Signers should follow the steps in the Remote Signer Policy to execute valid electronic signatures in e-Manifest.
3. Can the generator sign a manifest on behalf of a transporter?
No. While a transporter can sign a manifest on behalf of a generator, this is because the initial transporter is frequently the offeror of a shipment, and has the personal knowledge of the facts involved in a shipment’s preparation, and thus can sign the generator/offeror certification on the manifest. There is no similar authority for generators to sign manifests on behalf of transporters.
Federal and State Implementation
1. What does it mean if my state has not adopted the e-Manifest rule(s)? What if my state has not become authorized for the e-Manifest rule(s)?
Implementation and authorization of e-Manifest requirements are governed by unique provisions of the e-Manifest Act. The Act provides that all requirements issued under the authority of the e-Manifest Act shall go into effect federally on the effective date of the federal regulations. In addition, the Act requires that EPA implement and enforce the e-Manifest requirements consistently in all states until such time as the states are authorized for these requirements.1 Thus, EPA will be active in all states on the program’s effective date, implementing the federal e-Manifest requirements until the states are authorized. When the states are authorized for delegable provisions of the e-Manifest rules, the states will then be able to implement the delegable electronic manifest regulatory requirements. However, even after states are authorized for e-Manifest, EPA retains its primary responsibilities to operate and maintain the e-Manifest system, and to implement the user fee program and collect the user fees from the regulated community.
2. Is the EPA or the states required to enforce the e-Manifest system?
The e-Manifest system is an extension of the existing manifest system, which involves compliance and enforcement responsibilities for both EPA and the authorized states. However, there are certain user fee aspects of the e-Manifest requirements that are exclusively federal responsibilities and that are not authorizable or enforceable by the authorized states.
The e-Manifest Act also produced some significant differences with respect to state implementation of the Act’s requirements. First, electronic manifest and use conditions that are based on e-Manifest Act authority, are effective in all states as of June 30, 2018, which is also the launch date of the e-Manifest system. The Act provides that EPA initially implement and enforce electronic manifests, as well as the other delegable e-Manifest Act based requirements (e.g., the requirement to submit final paper manifest copies to the system, the use of hybrid manifests, and manifest data corrections) until such time as the states adopt these requirements in state law and obtain authorization for them. Second, the user fee requirements promulgated by EPA under the e-Manifest Act at 40 CFR part 264 subpart FF, are not authorizable or delegable to states, and are exclusively federal requirements that only EPA can implement and enforce. Only EPA can set e-Manifest user fees and collect them from the user community. Likewise, the financial and civil enforcement sanctions for non-payment that are set out in the e-Manifest rules are federal sanctions that only EPA can enforce against users who neglect to pay the fees owed to the Agency for their e-Manifest submissions.
EPA has developed a separate Q&A that discusses in greater detail the e-Manifest User Fee Rule and its authorization requirements.
3. Can states continue to collect paper manifests after e-Manifest launches?
States may continue to collect generator or transporter copies of paper manifest after e-Manifest launches, including hybrid manifests where the generator signs on paper. However, the receiving facility copies of manifests may only be collected by e-Manifest. States can obtain their receiving facility data from the e-Manifest system.
For electronic manifests, the EPA system collects and retains all handler copies from generators, transporters, and receiving facilities. Since states can obtain any handler copy of an electronic manifest from the e-Manifest system, states cannot require generators or other waste handlers to supply a paper or other copy of electronic manifests directly to the states.
4. What if a state receives a manifest form that should have gone to EPA?
If a state receives paper manifests intended for EPA, it should not process them. Instead, the state should:
- Contact the receiving facility to report the “misdirected” manifest error;
- Direct the receiving facility to EPA’s webpage, "How to Submit a Hazardous Waste Manifest"; and
- Return the “misdirected” manifests to the receiving facility by postal mail.
5. Can states collect a paper generator copy when the generator uses the electronic manifest?
No. States cannot require generators to print out electronic manifests and submit them to the state. States can receive their manifest copy from the e-Manifest system. A state may only collect a generator copy of a paper manifest when the generator signs on paper. This is because the EPA system collects only the receiving facilities’ paper copies, and not the paper manifest copy from generators, thus the paper copy will not be available to states from the e-Manifest system.
6. How will use of e-Manifest relate to the Department of Transportation (DOT) hazardous material regulations (HMR) requirement to use a shipping paper?
DOT currently requires that a hard copy shipping paper be placed in the cab of the transport vehicle during transportation. The system allows users to print electronic manifests that satisfy the DOT HMR requirement for a shipping paper.
7. Does the use of e-Manifest satisfy EPA and Department of Transportation (DOT) hazardous material regulations (HMR) recordkeeping requirements for retention of the manifest?
Yes. Proper use of e-Manifest satisfies the EPA RCRA recordkeeping requirements for hazardous waste generators, transporters, and receiving facilities. DOT HMR requires companies to retain a copy of the shipping paper (manifest), or an electronic image. DOT allows companies to retain shipping papers electronically, as long as a hard copy is provided to an authorized representative upon request. The retention periods supported by e-Manifest will meet or exceed DOT's three-year record retention requirements for hazardous waste shipping papers.
Fee Obligations
1. Is there a fee to use the e-Manifest system?
Yes, the e-Manifest Act authorized EPA to collect reasonable user fees for all system-related costs, including development and maintenance. In the final User Fee Rule, EPA determined that the destination or receiving facilities will pay a per manifest fee that will cover the costs of the e-Manifest system.
2. How much does the e-Manifest system charge per manifest?
EPA imposes a per manifest fee for each manifest submitted to the system based on the type (paper or electronic) and mode of submission (data plus image upload, scanned image upload). For more information on the current fees, visit e-Manifest User Fees and Payment Information.
3. Do I have to pay a fee if I make corrections in e-Manifest?
No. Under the final rule, there is no fee associated with data corrections which may be submitted any time after an original manifest has been submitted to e-Manifest.
4. What is EPA doing with the user fees it collects from e-Manifest?
The fees that EPA collects from e-Manifest and places in a U.S. Treasury account are to be used solely to offset EPA's costs in developing, operating, maintaining, and updating the e-Manifest program, as required under the e-Manifest Act.
5. How does e-Manifest handle rejected loads by the receiving facility and who pays the manifest user fees in this case? What about partial rejections?
If the entire shipment is rejected, the manifest rules allow the rejecting facility to forward the entire shipment to an alternate receiving facility on the original manifest. In such a case, the alternate facility is responsible for signing the manifest, submitting this manifest to the e-Manifest system, and paying the fee. If a waste is partially received and partially rejected by the original facility, the original facility is responsible for submitting the original manifest to the system and paying the related fee for the processing of the partial receipt data. The re-shipment of the rejected portion of wastes to another receiving facility requires a second manifest, and the alternate receiving facility designated on the second manifest to receive the rejected wastes is then responsible for submitting this second manifest to the system and paying its associated fee.
The submission and fee payment requirements differ somewhat for wastes that are rejected by the receiving facility designated on the original manifest, and then returned to the generator. This is because EPA does not require manifest submissions or fee payments by generators. If the entire shipment is rejected, the manifest regulations allow these wastes to be returned to the generator under the original manifest. In that case, the rejecting facility is responsible for submitting to e-Manifest the copy of the return manifest signed by the generator, which current manifest regulations require the generator to send back to the rejecting facility within 30 days. When submitting this return copy to the system, the rejecting facility must also pay the processing fee for the return manifest.
Likewise, for partial rejections that involve a return of rejected waste to the generator under the manifest discrepancy requirements, the receiving facility of the original manifest is responsible for submitting the signed copy showing its waste receipts to e-Manifest and paying this manifest’s processing fee. Since the return of the rejected portion of the waste shipment requires a second manifest to be completed by the rejecting facility to track the return shipment back to the generator, this facility is also responsible for submitting the return manifest copy (signed by the generator) to e-Manifest and paying the fee for the processing of the return shipment manifest. So, a partial rejection by a receiving facility that also involves a return shipment to the original generator can cause the rejecting facility to be responsible for two distinct manifest submissions and their related processing fees:
- The submission of the original manifest showing waste receipts by the receiving facility
- The submission of the copy of the return shipment manifest signed by the original generator
6. If the system is not available through no fault of the user, and a shipment’s tracking must be completed with a paper manifest, will I be charged the paper submission fee or the electronic manifest fee?
The e-Manifest regulations provide that in certain instances where the system goes down, such that the system is unavailable to complete the tracking of a shipment that was initiated with an electronic manifest, a paper “replacement manifest” must be used to complete the shipment’s tracking. This would likely only be an issue for shipments that begin under a fully electronic manifest or as a hybrid, as system outages should not affect paper manifest submissions sent via the e-Manifest system such as images, since the receiver can in most cases defer uploading the data files or image files until the system has been restored.
For extended system outages that are not scheduled and necessitate the use of a paper replacement manifest, EPA will invoice these shipments based on their submission to the system as paper manifests. EPA is obliged by law to recover its full costs for operating e-Manifest, so the Agency must generally charge the paper processing fee for paper manifests.
If there are exceptional circumstances (e.g., a system outage of unusual length) and a facility believes its charges under an invoice are unfair or improper, the facility may raise these circumstances through the invoice dispute process. In these exceptional circumstances EPA may adjust fee invoices to address such circumstances where good cause is shown, and the applicant can demonstrate the fee adjustment that would be appropriate for the affected transactions.
To initiate this invoice dispute process, please email e-manifestfinancialhelp@epa.gov.
Record Retention and Distribution
1. How long does EPA’s e-Manifest system keep manifest data?
EPA intends for the e-Manifest system to keep manifest data indefinitely until a formal records schedule can be established. EPA expects to consult with the e-Manifest System Advisory Board and obtain the Advisory Board’s advice regarding record retention protocols.
2. If I upload a paper manifest to EPA, what is considered the “legal” record of shipment once the paper manifest is submitted? Do I need to retain my paper copy or can I rely on the system to keep the electronic record?
The e-Manifest system is intended to be a national hub for the collection, distribution, and retention of electronic and specific paper manifest records. The system is particularly aimed at reducing the paperwork burdens under the prior paper-based system, by automating the transmission of manifest documents to interested waste handlers and states, and by providing a means for electronic record retention.
For electronic manifests, the e-Manifest system supports the entire manifest production, distribution, and record retention process for all the generators, transporter, and receiving facilities that establish accounts in e-Manifest and participate in electronic manifesting. The system distributes and retains in the relevant handlers’ accounts, all manifest copies produced and used during the tracking of a hazardous waste shipment, including the generator’s initial copy, the transporter copy, and the final copy signed by the receiving facility, which is distributed to the original generator, to the delivering transporter, and to interested states. Each of these electronic copies are secured and retained by the system as copies of record which can be retrieved and examined by persons authorized by each handler to view their company’s manifest records. These manifests can also be inspected by regulators. All manifest record retention and inspection requirements are satisfied electronically by users being able to access their copies of record through their accounts in e-Manifest.
For paper manifests, the manifest retention and distribution requirements of e-Manifest are more focused. The e-Manifest system collects and distributes only the final receiving facility copy, which is received as either a scanned image upload or a data plus image upload.
Since the e-Manifest system only collects the final receiving facility copy, generators must retain on site the initial paper copy bearing the generator/offeror signature and the signature of the initial transporter. Likewise, transporters should retain any paper copies they obtain in executing waste shipments that involve paper manifests, as these paper copies will be viewed as their legal copies of record.
The e-Manifest system also has the capability to transmit and store in handlers’ accounts the scanned images of the final manifest copies submitted by the receiving facilities. In such cases, the receiving facilities need only retain their on-site paper copies (Page 3- designated facility copy) until such time as a legible scanned image of the manifest is entered in the system and accessible to the facility by accessing its account in e-Manifest.
Likewise, a generator that chooses to use paper manifests, but that has access to an account in e-Manifest, may also take advantage of the system’s secure record retention and retrieval capabilities to satisfy its record retention requirements. A generator who uses paper manifests, but registers with e-Manifest and creates an account for monitoring manifest activity, may rely on the scanned image from the receiving facility as its final manifest copy. Since this image bears the signature of the receiving facility, and is securely stored by e-Manifest and accessible to the generator, this image suffices for the copy of record of the generator’s final manifest. This image copy replaces the paper copy that previously would have been mailed to the generator by the receiving facility.1 Note that this only applies to manifests that are executed throughout as paper manifests through the entire chain of custody ending with the hand signature of the receiving facility. Generators who use the hybrid manifest option – and keep a hand signed paper copy as their initial generator copy – cannot replace their initial paper copy with the final signed by the receiving facility. The final copy from the receiving facility is an electronic manifest signed electronically, and is not an image file that displays the hand signatures of all the waste handlers. Therefore, the generator using the hybrid manifest must retain its hand signed paper copy among its records for the entire record retention period.
1 EPA determined in 1996 that scanned images that bear the handwritten signatures of waste handlers are legally sufficient for record retention and inspection purposes, if the record retention systems used to produce, store, and retrieve these records are secure and provide reliable access. The e-Manifest system is designed to meet and exceed these requirements.
3. If I am an exporter, and I need a copy of the paper form to send to the foreign consignee facility, how do I do this if the new 5-copy form does not provide an extra copy for this purpose?
When using the new 5-copy form, an exporter should simply make a photocopy of the manifest and send the photocopy to the foreign consignee. This is the standard manifest procedure when there are insufficient copies in the form set to supply all handlers or interested parties with a copy of the manifest.
While EPA understands that exporters may have used Page 2 of the previous 6-copy manifest (designated as copy for destination facility to send to generator state, if required) to send to the foreign consignee facility, the copy designated as Page 2 in the previous 6-copy form was not actually intended for this purpose. It was available, however, as an extra copy for exporters or others to use when convenient.
With the new 5-copy form, there is no longer a copy earmarked for the designated facility to send to a generator state. This copy is no longer available for use as an “extra” copy. So, a photocopy of the manifest should be made by exporters or others who need an additional manifest copy for any other purpose.
4. For paper manifests, is the data file or the scanned image the legal copy of record?
The data file, scanned image, and any post-receipt corrections submitted through the e-Manifest corrections process all comprise the e-Manifest copy of record, and all components are relevant for state and federal enforcement purposes.
EPA has received questions regarding the language in paragraph (3) in the definition of “user of the electronic manifest” at 40 CFR section 260.10. EPA is clarifying that the above language refers to the actual physical paper copies mailed to EPA’s paper processing center (PPC); these physical paper copies were not official copies of record and were recycled once the PPC completed processing the manifest in e-Manifest (note that EPA no longer receives mailed paper manifests as of June 30, 2021).
Data Policy and Data Correction
1. How does the e-Manifest system allow for corrections? Who can correct a manifest?
EPA has implemented a manifest data corrections process that enables any interested person to submit data corrections at any time after the receiving facility copy and data have been entered in the system. It is available to e-Manifest registered system users and works in the following manner.
After the receiving facility submits its signed copy of a manifest (whether paper or electronic) to e-Manifest, interested persons, including the named waste handlers on the manifest as well as state regulators performing Q/A activities from the generation or destination states, may submit data corrections to the system. This can happen at any time post-receipt. Waste handlers must certify that the corrected data are accurate and complete, and the submission of a correction generates an automatic notice to the other persons associated with the manifest. These other interested persons may then respond to a correction notice with their own data corrections. The system retains an auditable record of all such correction submissions, and the latest correction made with respect to a manifest is regarded as the final and correct representation of the data. Thus, the data corrections process is an open process, conducted electronically among the interested waste handlers and state regulators connected with a manifest.
2. How does e-Manifest address Confidential Business Information (CBI)?
EPA has determined categorically that manifests are not subject to CBI claims. Refer to 40 CFR section 260.2(c). For many years, a number of authorized states have been disclosing their manifests and manifest data freely to the public upon request, and have not subjected these public requests for data to CBI scrutiny. Since manifest data have been and will remain freely available from those states, EPA is not according CBI status to manifest data. Therefore, it is not necessary to establish any formal process for addressing CBI issues in e-Manifest.
3. When does e-Manifest data become available to the public?
The public generally has access to manifest data 90 days after the date of receipt at the receiving facility. EPA believes that 90 days is a generally sufficient time for the waste handlers involved with manifests to sort out discrepancies, correct data , or address other issues connected with a manifest, although there is no fixed time limit on data corrections.
In addition, certain data from manifests that may involve the shipment of Chemicals of Interest (COI) under chemical security rules issued by the Department of Homeland Security (DHS) are redacted from manifests before they are made available to the general public.
4. Will EPA disclose information from manifests withheld from public disclosure as part of a Freedom of Information Act request?
EPA will not publicly disclose through the e-Manifest system certain information from manifests involving P-List and U-List RCRA wastes if they are included on the Department of Homeland Security (DHS)’s Chemicals of Interest list found at the appendix to 6 CFR part 27. These data would not be available for disclosure to the public under a Freedom of Information Act (FOIA) request.
5. How are discrepancy reports handled in e-Manifest?
Under the federal RCRA hazardous waste regulations, if receiving facilities cannot reconcile discrepancies with the waste generator or transporter within 15 days after receiving the waste, the receiving facility must submit to the regulator a letter describing the discrepancy and attempts to reconcile it and a copy of the manifest at issue. This is known as the “discrepancy report.”
The final rule’s new correction process does not displace the existing discrepancy reports, however, EPA expects use of the system to result in fewer discrepancy reports needed since waste handlers have the opportunity to participate in an open corrections process after the manifest is signed by a receiving facility. The receiving facility can identify errors and correct them as part of the corrections process, which also permit a generator to respond to such corrections. Thus, waste handlers are expected to reconcile data errors, including discrepancies, as part of this corrections process. However, there is still a role for the discrepancy reports to address significant discrepancies in quantity and type that are not resolved by the corrections process. If the generator and the receiving facility do not agree to a facility’s correction, or the generator is not a participant in such corrections, then the facility should still file the discrepancy report when there is an unresolved discrepancy in piece count for container shipments, or an unresolved discrepancy of greater than 10% with respect to a received bulk shipment. This has the effect of elevating unresolved discrepancies to the attention of regulators and remains necessary in those cases where corrections are not able to provide a satisfactory resolution to a shipment discrepancy.
6. After I make corrections, what version of the manifest will be used in an enforcement case?
Both the final copy of the manifest signed by the receiving facility (including the image and data files) and corrections introduced later by the corrections process may have relevance. The original manifest document is a shipping paper, and the copy of the manifest signed by the TSDF at receipt represents the facility’s certification of receipt. The data corrections process is intended to provide an orderly process for correcting data records in the system, and all corrections certified and entered will be retained and audited by the system, with the original records including any uploaded images of the paper manifests.
7. Is the e-Manifest system linked to RCRAInfo?
Yes, the technical elements of e-Manifest are housed within RCRAInfo and, as such, has the ability to validate information entered on an electronic manifest against information in RCRAInfo. RCRAInfo is an EPA information system that collects information on hazardous waste sites. The public can access information in RCRAInfo through RCRAInfo Web.
8. Will use of the e-Manifest system replace the federal biennial report (BR)?
The e-Manifest Act requires that EPA integrate the reporting of information in e-Manifest with the RCRA biennial report process. EPA remains committed to that goal, but will phase in this feature over time to ensure that manifest data are of high quality to support state and federal processes. The use of e-Manifest has not yet replaced the biennial reporting requirements.
9. How should discrepancy, exception and unmanifested waste reports be handled in light of the e-Manifest System?
The three reports are currently independent reporting requirements separate from the e-Manifest system; however, EPA is exploring whether these reporting requirements can be incorporated into the system.
10. What are the responsibilities of the EPA Regions and authorized states for handling discrepancy reports that are filed by the receiving facilities?
Discrepancy reports are required from a receiving facility under 40 CFR section 264.72 (and equivalent authorized state regulation) when the facility discovers there is a “significant discrepancy” in the quantity or type of waste received that cannot be reconciled with either the generator or transporter within the 15-day period allowed by the regulations. Until EPA decides to take any final action to incorporate discrepancy reporting in e-Manifest, a discrepancy report, consisting of: (a) a letter describing the discrepancy and reconciliation attempts, and (b) a copy of the manifest at issue, must be mailed to the Regional Administrator, or State Director (if the state is authorized to implement the RCRA program).
The response, if any, by the EPA Region or state to a discrepancy report is entirely at the discretion of the agency. The discrepancy report is intended to bring to the attention of the regulator that there was a shipment that presented a significant discrepancy which could not be resolved through the efforts of the affected waste handlers. The agency officials receiving the discrepancy report may choose to engage in follow-up with the waste handlers to determine the reasons for the discrepancy and its consequences. The agency might, for example, determine that it is appropriate to schedule an inspection at one or more of the waste handlers involved in the shipment. If appropriate, the regulator may take an enforcement action where it determines that the facts surrounding the discrepancy suggest a RCRA violation has occurred.
Similar considerations apply to Exception Reports and Unmanifested Waste Reports, which like the Discrepancy Report, are intended to alert the EPA Region or state that an irregular event in the manifest process occurred, and that this event may merit some follow-up action at the discretion of the regulator.
11. For state-only hazardous wastes transported out of the generator state, can an interim facility listed as the designated facility on the generator’s manifest close out that manifest and re-ship the waste to another (and final) destination facility on a bill of lading (provided both the interim facility and final destination facility states do not regulate the waste as hazardous waste)?
For purposes of this FQ, EPA intends for the term “interim facility” to mean any facility that receives waste prior to the shipment of waste to an ultimate management facility. If the interim facility is permitted, licensed, registered, or otherwise authorized by a state to manage non-hazardous waste, then the interim facility may close out the manifest. To properly close out the manifest, the interim facility must take the following actions: (1) the interim facility must receive prior approval from the generator to be named as the designated facility on the manifest; and (2) the manifest must list the interim facility—rather than the originally named receiving facility -- as the designated facility. After the interim facility takes these actions, then it can close out the manifest, and the wastes can be subsequently re-shipped to an ultimate management facility (also located in a state in which the waste is non-hazardous) on a bill of lading. The interim facility must sign and date the manifest and submit it to EPA for data processing. The interim facility must register in e-Manifest to submit the manifest and pay the associated fee for the manifest submission.
12. How is the above answer affected if the interim facility is a transfer facility?
A transfer facility cannot close out the manifest even if the generator designates the transfer facility on the manifest as the receiving facility. EPA defines “transfer facility” to mean: “any transportation-related facility, including loading docks, parking areas, storage areas and other similar areas where shipments of hazardous waste or hazardous secondary materials are held during the normal course of transportation.” Refer to 40 CFR section 260.10. A transfer facility does not meet the definition of a designated facility for purposes of the manifest because it can only store waste shipments temporarily, up to ten days, without a permit during the normal course of transportation to the designated facility. Refer to 40 CFR section 263.12(a). The original manifest remains active during the time that waste is temporarily stored at a transfer facility, so the waste shipment must leave the transfer facility under the same manifest under which it arrived. Thus, a transfer facility cannot be the designated facility on the original manifest, and the manifest cannot be closed out at a 10-day transfer facility. A transporter must transport the waste and the accompanying manifest from the transfer facility to a receiving facility designated on the manifest.
System-Specific Questions
1. Is e-Manifest accessible on mobile devices, like a tablet or smart phone?
Yes, e-Manifest is accessible on mobile devices through your favorite browser at https://rcrainfo.epa.gov/.
2. Can you print out a hard copy of an electronic manifest?
Yes. You can print a hard copy of an electronic manifest by selecting the printer icon in the top right corner of the manifest (shown below).
3. Can e-Manifest be used for both hazardous waste and non-hazardous waste shipments on the same truck?
Yes
4. What is the difference between Quick Sign and CROMERR signatures?
The Quick Sign signature applies to electronic signatures for initial receipt of shipments by generators, transporters, and receiving facilities. The CROMERR-compliant signature applies to electronic signatures for receiving facilities submitting the final manifest to EPA or to users (e.g., generators, transporters, and receiving facilities) submitting post-receipt corrections to the e-Manifest system. CROMERR-compliant signature method require a higher level of identity proofing and requires users to answer a challenge question to electronically sign.
Another key difference is that Quick Sign is available for users with Preparer permission, unlike the CROMERR-compliant signature method, which requires users to have Certifier or Site Manager permission, including completion of an Electronic Signature Agreement. Certifiers and Site Managers can also Quick Sign.
5. Can I sign electronic manifests in my company’s system?
Yes. As of February 2023, sites can use their company’s software to initiate the electronic signature process through the RCRAInfo application programming interface (API). Developers and IT personnel can find documentation on using the API in the USEPA/e-Manifest GitHub repository. The Remote Signer Policy describes how sites can build their systems to sign electronically through system-to-system communication.
The e-Manifest system also provides a service that returns hyperlink and allow industry systems to send their users directly to the manifest(s) they need to sign in RCRAInfo. The users will still need to log in to the system, but they will save themselves time by going directly to the manifest(s) they need to sign.
6. Will Quick Sign and CROMERR signatures be shown differently on the printed PDF of the electronic manifest?
No. Quick Sign and CROMERR electronic signatures are identical on the printed manifest.
7. I have over 100 manifests to upload. Do I have to sign each one separately?
If your site’s EPA ID was approved via myRCRAid
You will need to submit a request to have your permissions changed. First, log in to the RCRAInfo Industry Application, click on your name in the upper right of the screen, then select “Profile,” select the “My Site Permissions” tab, and pick the site for which you need to change permissions. Click on the “Modify Permissions” button and select the desired permission level for each of the modules you need (i.e., myRCRAid, Biennial Report, or e-Manifest). If you will be managing permissions of other users, you must set the “Site Manager” drop down, located at the top of the box, to “active.” (When doing this, the other available modules will disappear.) Once you select your permission levels, click the “Send Requests” button. If you are the first Site Manager for the facility then your request will go to the appropriate state or EPA contact. If you are not the first Site Manager, then your request will go to any currently registered Site Managers for approval.
If your site’s EPA ID was approved outside of myRCRAid
If you do not yet have a RCRAInfo Industry account, go to the RCRAInfo Sign in page to begin the user registration process. Once approved, search for the site and request access. Following approval from either the Site Manager, state, or EPA, you can begin using the e-Manifest system. More information is available at e-Manifest User Registration.
9. If there are more than four waste line items, does the system create a continuation sheet?
Yes. The continuation sheet can be printed as well.
10. If drivers do not have network access, how do they sign electronically?
EPA’s Remote Signer Policy allows Remote Signer personnel to execute electronic signatures through their employees or contractors who are remotely located from the hazardous waste shipment. If a driver can communicate the necessary information to a Remote Signer, which is a remotely located individual with network access and sufficient permissions in e-Manifest to electronically sign, then the Remote Signer can execute the electronic signature in the e-Manifest system for the driver.
If the driver otherwise has access to a computer or smart phone, they can sign electronically in EPA’s e-Manifest system.
11. Does e-Manifest use EPA's Central Data Exchange (CDX)?
Yes. e-Manifest is one RCRAInfo Industry Application which utilizes CDX for its registration. Users registered with existing CDX accounts simply need to login via the RCRAInfo Industry Application to gain access to the application. Unregistered users can register directly with the RCRAInfo Industry Application. All users need to request permissions for their specific site(s) once they gain access.
12. Can generators add the management method code at the initiation of the manifest?
Under the current paper-based manifest system, the receiving facility enters the management method code. In e-Manifest, the management method code is optional up until the point the manifest is finalized and sent to EPA. This means a user may enter a management method code on the manifest at any point, but the receiving facility must enter/ensure the code is entered after signing for receipt of the waste and before the manifest is electronically signed and placed on the receiving facility's invoice.
13. Are state hazardous waste codes included in e-Manifest?
Yes. States have provided this information to EPA and it is available in the system along with all federal waste codes.
14. I have a state-issued ID, but when I conduct a search for the ID in the e-Manifest system, it says there are no results to display. How do I have my state-issued ID Number added to e-Manifest?
State-issued IDs that are not also EPA IDs are not currently in the federal system, which is why you are unable to find it when searched. Please visit State Contacts and contact the appropriate state person and they will assist.
15. Can I create a manifest template? For example, for repeat shipments?
Yes, users can simply use the copy manifest icon on the e-Manifest dashboard.
16. What role does e-Manifest play in supporting emergency response?
A Site Manager or state administrator can choose to grant emergency responders view access to their site or state information, respectively. However, transporters must continue to carry a shipping paper on the transport vehicle for the use of responders, in accordance with current DOT requirements. For this reason, the e-Manifest system is not being designed for emergency response purposes.
17. How does e-Manifest handle multiple handling codes for a single manifest line item (e.g., lab packs)?
A company may include as many waste codes as they need on each waste line.
18. Are there “flexfields” for tracking additional information that isn’t required by EPA?
Yes, in the e-Manifest system we refer to this as “reference information” and we have made “reference information” options available both at the manifest level and the individual waste line level.
19. How are password resets handled in e-Manifest?
Password resets may be requested via the e-Manifest application. Users may do so via their user profile (by selecting their name in the top right corner of the screen) or by selecting the “forgot password” link. Passwords expire every 90 days and can be reset using the “forgot password” link.
20. Can I sign electronic manifests on paper?
Under the Hybrid option, the generator can can sign on paper. Once a generator (or initial transporter under the hybrid manifest approach) signs electronically, all subsequent entities must sign electronically.
21. Does e-Manifest allow use of decimals in the quantity field?
No, the current paper manifest system does not allow for decimals.
22. Will e-Manifest allow for printing of hazardous waste labels?
No.
23. I tried to sign an Electronic Signature Agreement (ESA), but it said I failed and had to send a paper copy. That window then closed, so how do I get back in to print a paper copy?
Log into your RCRAInfo Industry account. You will have an orange banner across the top of the screen with a link that will take you to your paper ESA, which you can then print. Alternately, you can click on your name in the upper right corner and select “Profile.” Once inside your profile, select the “My e-Signature Agreements” section and there will be an option to re-download the ESA so you can print, sign, and then mail it in or provide it to your Site Manager.
24. How do I reset my electronic signature questions?
There are two ways to reset your electronic signature questions:
- Via RCRAInfo Industry Application
- Log in to RCRAInfo and click on your profile name in the top right of the screen and select PROFILE.
- Select the Reset Signature Questions button located on the bottom of the page.
- Enter the password you used to log in to the application and select Send Verification Code.
- This will send a verification code to the email address associated with your account.
- Enter the verification code into the box.
- You will now be prompted to select and answer five security questions.
- The answers you enter are case, space, and character sensitive within the system.
- Once you have completed the entries, click Save to complete the reset process.
- Via CDX Account
- Access your CDX Account.
- Once you have accessed your CDX account, click on the My Profile tab.
- Locate and click the Modify Verification Methods button in the Verification Methods box.
- In the Verification Methods section, click the Blue Edit link.
- Enter your CDX password in the open field and click Send button.
- An email will be sent to your account on record with an authorization code for use in resetting the questions.
- In your CDX account, click on your MyCDX tab at the top of the page.
- You will find an Alert on the right-hand side of the page regarding your eSIG-Pin Signature Questions.
- Click on the word here within the Alert message (It is a blue link). This action will take you to another page where you will find a blank field.
- You will now be required to access your email account and locate an email message from helpdesk@epacdx.net.
- Open the email where you will find a long code within the email. Highlight and copy this code. You will then paste the authorization code from the email into the open field on the CDX account page.
- Once you have completed this action, click the Update button.
- You will now be prompted to select and answer five security questions.
- The answers you enter are case, space, and character sensitive within the system.
- Once you have completed the entries, click the Save Answers button to complete the reset process.
25. I can’t find my manifest. What is going on?
There may be a couple of things going on:
- If you (or your receiving facility) submitted the paper manifest via scanned image upload, it’s possible your manifest has not yet been entered into the e-Manifest system by the EPA Paper Processing Center.
- It’s possible that a manifest is not appearing for you if your EPA ID number from the paper manifest was not entered correctly. For example, if the receiving facility mistyped your EPA ID number from the paper manifest or used a generic “VSQG” or “CESQG” rather than entering your EPA ID.
To prevent this type of error, we encourage receiving facilities to use the “Search for Generator” button in e-Manifest. This button will then populate name/addresses/phone/email automatically on the manifest.
If your receiving facility uploaded a data plus image manifest or used an electronic manifest and you still can't find the manifest, please contact your receiving facility to confirm the EPA ID number they entered for you.
If you receive an email from a state agency or EPA asking you to correct manifest data, please do so!
26. How long do remote signers have to execute an electronic signature?
Remote signers have until the earlier of either (i) 24 hours from the time that their field personnel receives the waste from the preceding waste handler (i.e., generator or transporter) or (ii) before transferring the waste to another handler (i.e., another transporter or receiving facility), to execute an electronic signature to the hazardous waste manifest.
Example 1. A truck driver contacts their dispatcher that they received waste at 11:00 AM on a Tuesday. The remote signer has until 11:00 AM on Wednesday to execute the electronic signature.
Example 2. A truck driver contacts their dispatcher that they received waste at 11:00 AM on a Tuesday and will drop it with another waste hauler at 5:00 PM that same day. The remote signer has until before the transfer of custody occurs (in this case, 5:00 PM Tuesday) to execute the electronic signature.
User Registration
1. Does each person need to register for e-Manifest? Or can there be one company account shared by multiple users?
While RCRAInfo accounts must be associated with an individual, the Remote Signer Policy stipulates that a Remote Signer user with sufficient permissions can execute electronic signatures for manifests where a field personnel with first-hand knowledge of the hazardous waste shipment has authorized them to do so.
2. What is the current user registration process for e-Manifest?
Please refer to our "How to Register for e-Manifest" page for further information.
3. Does EPA charge a fee for registering?
No, EPA does not charge a fee for registering or holding an account with e-Manifest.
4. I’m registered on the RCRAInfo test site, Preprod, do I need to re-register in RCRAInfo to participate in e-Manifest?
Yes. Users testing e-Manifest who have registered in the RCRAInfo pre-production database must also register in the RCRAInfo production database. Because these are two separate databases, you must register for each separately. Please refer to Step 3: Register for e-Manifest in RCRAInfo under “How to Register for e-Manifest” for further information.
5. I already registered and requested access to the myRCRAid/Biennial Report/WIETS module, do I need to register for e-Manifest?
If you registered as a Site Manager, you do not need to reregister or adjust your account for e-Manifest. If you registered as a viewer, preparer, or certifier you will not need to re-register, but you will need to request and be granted access by your Site Manager to your specific sites. You may do so via your user profile (by selecting your name in the top right corner of the screen).
6. What are the permission levels for e-Manifest?
There are three permission levels in the e-Manifest module: Viewer, Preparer, and Certifier. These permissions are hierarchical so each permission can perform the functionality of the levels before it as well as the specific functionality for that given permission (i.e., a Preparer can do everything that a Viewer can do, and a Certifier can do everything that a Preparer and Viewer can do). Additionally, the RCRAInfo system offers a Site Manager Permission level which applies to all modules currently available in the system, including the e-Manifest module.
Functionality for e-Manifest | Viewer | Preparer | Certifier | Site Manager |
---|---|---|---|---|
View manifests |
X |
X |
X |
X |
Create manifests, edit Draft manifests, and complete non-CROMERR compliant signatures. |
N/A |
X |
X |
X |
Complete CROMERR compliant signatures, correct manifest data electronically, and submit manifests. |
N/A |
N/A |
X |
X |
Approve users and grant permissions (i.e. Viewer, Preparer, Certifier, and Site Manager) to other company contacts at a site. View billing invoices for a site as well as submit payments. |
N/A |
N/A |
N/A |
X |
7. What is a Viewer?
As a Viewer, you can view manifest forms (i.e., the manifest, EPA Form 8700-22 and continuation sheet, 8700-22A) and data for specified sites within the e-Manifest module, but cannot create manifest forms, edit the information, or sign manifest forms.
8. What is a Preparer?
As a Preparer, you can perform the same functionality of a Viewer and also enter or edit data for specified sites within the e-Manifest module. Preparers can use the “Quick Sign” feature to complete non-CROMERR compliant signatures, However, Preparers cannot complete CROMERR compliant signatures which are required when submitting the final manifest to the e-Manifest system.
9. What is a Certifier?
As a Certifier, you can perform the same functionalities of a Viewer and Preparer, and can also complete CROMERR compliant electronic signatures and submit manifest information to EPA for specified sites within the e-Manifest module. As a Certifier, you are required to obtain an Electronic Signature Agreement.
10. What is a Site Manager?
As a Site Manager, you can perform the same functionalities as a Viewer, Preparer, and Certifier for e-Manifest as well as the other modules in the RCRAInfo Industry Application (i.e., myRCRAid and BR). In addition, you can approve and grant permissions to other contacts in your organization to sites for which you have Site Manager permission. As a Site Manager, you are also required to obtain an Electronic Signature Agreement and have the option of managing Electronic Signature Agreements for others in your organization. You may also be responsible for managing your company’s Application Programming Interface key, as applicable. If a receiving company, you have access to view and pay user fees through EPA’s RCRAInfo system.
11. What is a Remote Signer?
A Remote Signer is a registered RCRAInfo user with sufficient permissions to sign electronic manifests. In order to act as the Remote Signer, the individual would need at least Preparer level permission in the e-Manifest module for the site’s EPA ID they are signing for. Certifier or Site Manager level access would also allow an individual to act as a Remote Signer. (Note that Remote Signer is not a separate permission level.)
A Remote Signer can also be the individual that holds the application programming interface (API) ID and keys that is used by their company’s software to communicate with e-Manifest. Currently, to obtain an EPA ID and key and use the RCRAInfo API, the Remote Signer needs Site Manager level access to the site that will be signing.
12. How is the Site Manager Permission different than the lower permissions?
RCRAInfo currently has three “industry applications” available to allow for electronic submission of three RCRA forms (i.e., Site Identification Form (EPA Form 8700-12), Biennial Report (EPA Form 8700-13), and the Manifest Form and Manifest Continuation Sheet (EPA Form 8700-22 and EPA Form 8700-22A). Unlike the lower permission levels, Site Manager applies to all three modules. In other words, a user granted Site Manager permission for a site would automatically have Certifier permissions for all three modules. However, a user who requested Certifier permission for e-Manifest would receive this permission only for the e-Manifest module (and not for myRCRAid or BR). This user would need to submit individual requests for similar permissions in the myRCRAid and BR modules. In addition, Site Management permission gives you the ability to approve and grant permissions to other users for your site.
13. Who qualifies for a Site Manager?
EPA has not set formal criteria for the Site Manager designation, so organizations have flexibility in their decisions. However, some suggestions for Site Manager include:
- At least one Site Manager who is responsible for managing personnel.
- At least one Site Manager who is responsible for a company’s information technology systems (e.g., someone who can help manage the company’s Application Programming Interface (API) key and electronic signature agreements).
- At least one Site Manager who has the ability to pay invoices on behalf of the company if the site is a TSDF (e.g., someone who can pay user fees).
14. What if EPA receives a request for a lower level permission and there is no Site Manager assigned/approved yet?
EPA strongly encourages sites to assign a Site Manager and will prioritize Site Manager permissions. In the absence of a Site Manager, EPA will approve user requests for lower permission levels until a Site Manager has been assigned. Following that approval, the Site Manager will then approve users within their organization.
15. Am I required to complete an Electronic Signature Agreement (ESA)
If you register as a Certifier or Site Manager and have not previously completed an electronic signature agreement, you will be required to complete an ESA as part of the registration process. Following EPA approval of your RCRAInfo account, you will be presented with an electronic signature agreement the first time you log in. At that time, you must complete the ESA. ESAs can be conducted electronically or via a handwritten signature.
16. Does a Site Manager need an ESA for each site/EPA ID?
No. A user only needs to complete an ESA once. A Site Manager is not required to complete additional ESAs for subsequent site additions.
17. I couldn’t successfully complete or get approval for the online ESA, what do I need to do?
If you do not gain approval for your ESA online, you must prepare and submit a subscriber agreement (a paper electronic signature agreement signed by an individual with a handwritten signature) and provide it to your Site Manager. If your site does not have a Site Manager (or you are the initial Site Manager for your site), then you will have to provide the paper ESA to EPA or your state. (The address for where to mail your ESA will appear on the bottom of the paper ESA.)
18. I couldn’t find or add my site in the e-Manifest module, what do I need to do?
To add a site, you must click the "Add Existing ID" button in the e-Manifest module to add an existing site location. If the site does not exist in the system, you must click the "Request Site ID" button to obtain a Site ID using the Site Identification Form (EPA Form 8700-12) and follow the instructions regarding the site addition process.
19. In which states can I electronically request an EPA ID ?
You can request an EPA ID in states that have opted into the myRCRAid module, which is the equivalent of filing the Site Notification form (form 8700-12). You can view up-to-date information on which states have opted into which myRCRAid and the other modules in RCRAInfo. Once you have an EPA ID number for your site, along with a registered user with sufficient permissions, you can start using e-Manifest for electronic manifesting and record retention.
Regulatory users can find this information in their settings under “State Participation”. Industry users can find the same information from the homepage under “Documentation”.
20. How is my company’s information added to e-Manifest?
A site’s information is added to e-Manifest via EPA’s Site Identification form (EPA Form 8700-12). (Sites that have already submitted an EPA Site Identification Form and have an EPA ID as a result, are already part of EPA’s RCRAInfo system and are retrievable through e-Manifest.)
If your site has not yet submitted a Site Identification Form/does not have an EPA ID, you can submit a Site Identification form to obtain an EPA ID and add your site to EPA’s RCRAInfo and e-Manifest systems. Additionally, if a generator does not have an EPA ID, generator information can always be manually added to the manifest (by a transporter or receiving facility, for example) which can then be copied for subsequent manifests.
The system does allow transporters and receiving facilities to manually enter generator information in the system, such as under the hybrid manifest, where the generator is not registered in e-Manifest. However, manual entry of generator information is not retained as a retrievable “record” in the system, unless added through the Site Identification Form.
21. If I create an e-Manifest account, can I share my login and password to sign electronic manifests?
No, accounts must be unique to individuals. However, a Remote Signer can execute electronic signatures through their own account for fellow employees and contractors who have first-hand knowledge of the waste shipment. The Remote Signer should provide the printed name of the unregistered coworker during the signature process.
Invoices/Payments
1. Who should I contact if I have questions about my invoice?
If you have any issues with your invoice, contact e-manifestfinancialhelp@epa.gov to reach EPA financial staff that can address your issues. In your email, please provide your name and the facility where you work, the EPA ID number of your facility, your contact information, the invoice date in question, the manifest tracking number(s), and the nature of the invoice issue. EPA staff intend to resolve your concerns within ten business days of receipt.
2. What happens if I pay my invoice late?
You are required to pay your invoice in the calendar month that it was received, or you will begin to accrue late fees. These fees include a monthly handling charge and a penalty on the principal of the bill for each month your bill remains unpaid. If your bill is unpaid 120 days after receiving it, it will be forwarded to the U.S. Treasury Department for collections and further action. Additionally, non-payment of your bill could subject your facility to enforcement action.
3. Who has the ability to view and pay invoices?
Site Managers receive a copy of their invoice electronically on the first day of the month after their manifests were submitted to EPA. This invoice summarizes the manifest activity for the facility in the prior month and also identify all manifests that were sent to EPA.
The electronic payment methods that are accepted in this system include a commercial credit card, a commercial debit card, and Automated Clearinghouse (ACH) debit. Checks or any other forms of payment sent directly to the EPA will not be accepted.
4. Do I need an account on Pay.Gov to pay my invoice?
No, we have simplified the invoice payment process to allow you to make your payments to Pay.Gov directly through e-Manifest. The invoicing and payment process provided through e-Manifest is the exclusive means supported for e-Manifest fee billing and payments.
5. Who is responsible for paying an invoice if your company ownership has changed?
If you are a receiving facility whose ownership has changed, but still have an active invoice that needs to be paid, you must work with the new ownership to identify who must pay the invoice. EPA requests that the new ownership identify who must pay this invoice to prevent the accrual of late charges. Regardless of any ownership changes, outstanding manifest invoices must be paid.
If the invoice is to be paid by an active Site Manager registered in e-Manifest, please send an email to e-manifestfinancialhelp@epa.gov and indicate which facility is responsible for paying this invoice.
If the invoice is to be paid by someone without an active Site Manager account in e-Manifest, please have this person(s) register with RCRAInfo.
6. How do I dispute a charge on my invoice?
If you believe there is an error with your invoice, you can request a review by EPA financial staff by emailing e-manifestfinancialhelp@epa.gov. EPA staff will research your claim and expect to inform you of their decision via email within ten business days of receipt.
If you are unsatisfied with this initial decision, you have ten business days of receiving that decision to appeal. The appeal will go to the Director of EPA’s Office of Resource Conservation and Recovery for a final decision. You can initiate an appeal by contacting e-manifestfinancialhelp@epa.gov.
EPA will inform you of this appeal decision via email within ten business days of receipt.
For more information on what you should include in these disputes, please refer to EPA’s e-Manifest Fact Sheets for User Types website.
7. Do I need to pay if I am disputing an invoice?
While in dispute, you are not required to pay your invoice; however, late fees will continue to accrue.
If EPA staff resolve the dispute in your favor, late charges will be waived. Otherwise, you will be required to pay any applicable late fees. You can avoid late fees by paying the disputed invoice up front; EPA will reimburse the invoice if the dispute is resolved in your favor.
Refunds from invoice adjustments are made via the same method of payment used to pay the invoice. If you have not paid your invoice and are due an adjustment, you will receive an updated invoice.
EPA cannot issue a credit for use on any future invoices.
8. If I work for a federal agency that receives federal or state regulated waste accompanied by a required RCRA manifest, how do I pay my invoice?
If you work for a federal non-military facility, the Site Managers registered with your facility will receive an invoice in e-Manifest. To make a payment, you can initiate a transfer between agencies, which can be done through the Intra-Governmental Payment and Collection (IPAC) system. To complete the transfer, you will need to obtain the EPA’s Agency Location Code (ALC).
If you work for a federal military facility, the Site Managers registered with your facility will also receive an invoice in e-Manifest. However, to make a payment, you can submit an SF-1034 to your local finance office, which will forward to the Defense Finance and Accounting Services (DFAS). Funds will be disbursed to the EPA by DFAS through the IPAC system. To complete this transfer, you will need to obtain the EPA’s Data Universal Numbering System (DUNS) and the Commercial and Governmental Entity (CAGE) number. as well as the ALC.
To obtain these specific codes, please contact e-manifestfinancialhelp@epa.gov.
9. What is a W-9 form, and do I need one to make a payment?
A W-9 form is a tax form developed by the IRS that allows users to certify they are making payments to authorized companies/organizations. This form includes the EPA’s Tax Identification (ID) number, which certifies that the EPA is a registered organization. Although the EPA does not require a W-9 form to make a payment, some companies require this tax ID number in order to authorize payments to the EPA. Your accounting staff should be able to determine if you need this information.
To request a completed W-9 form, please contact e-manifestfinancialhelp@epa.gov.
PCBs
1. Do record retention policies differ for RCRA and PCB wastes tracked with the RCRA manifest?
No. Record requirements for both RCRA hazardous waste and Regulated PCB waste manifests are the same; both must be kept for three years under EPA’s federal regulations.
2. Does waste containing Toxic Substances Control Act (TSCA)-regulated Polychlorinated Biphenyls (PCBs) need to be manifested for disposal?
Yes. Unless specifically exempted from the requirements in 40 CFR part 761 subpart K. The PCB regulations require generators to prepare a manifest on EPA Form 8700-22, and, if necessary, a continuation sheet prior to transporting regulated PCB waste. Regulated PCB waste(s) means those PCBs and PCB Items that are subject to the disposal requirements of 40 CFR part 761 subpart D. Refer to 40 CFR section 761.207 for more information.
3. Is a manifest necessary for PCB waste that is not regulated under federal TSCA regulations, but which is regulated by the state?
Yes. Waste containing PCBs that is not regulated for disposal under TSCA federal regulation (e.g., transformers containing < 50 ppm PCBs) may still be regulated by state waste programs. If the PCB-containing waste is regulated by the state where the waste is generated or the state where the waste is received, use EPA Form 8700-22, leave Box B blank and complete Box C. For convenience, refer to the table below for state-specific waste codes pertaining to PCBs, which are also available in the e-Manifest system. This list may not be complete; contact the state regulator for more information.
Waste Code |
Description |
California |
|
261 |
PCB and other material containing PCBs |
Illinois |
|
IL04 |
PCB1 Solids (Capacitors, Transformer Carcasses) |
IL05 |
PCB2 Liquids (Transformer and Capacitor Oils, etc.) |
Maine |
|
M002 |
PCB Content of 50 ppm of higher |
MRM002 |
Universal Waste PCB |
Maryland |
|
M001 |
Polychlorinated biphenyls (greater than 500 ppm) |
MT01 |
Polychlorinated biphenyls (50 to 500 ppm) |
MX01 |
Mixtures of soil, water, or debris containing PCBs with concentrations greater than 50 ppm or any residue resulting from the cleanup of a spill of any commercial chemical product or manufacturing product having the generic name listed in COMAR 26.13.02.19E and G |
Massachusetts |
|
MA02 |
PCB Wastes |
Michigan |
|
026L |
PCB Waste |
Minnesota |
|
MN03 |
PCB Waste |
Nevada |
|
PCBX |
Generic PCB Waste |
New York |
|
B001 |
PCB Oil (concentrated) from transformers, capacitors, etc. |
B002 |
Petroleum oil or other liquid containing 50 ppm or greater of PCBs, but less than 500 ppm PCBs. This includes oil from other electrical equipment whose PCB concentration is unknown, except for circuit breakers, reclosers and cable. |
B003 |
Petroleum oil or other liquid containing 500 ppm or greater of PCBs. |
B004 |
PCB articles containing 50 ppm or greater of PCBs, but less than 500 ppm PCBs, excluding small capacitors. This includes oil-filled electrical equipment whose PCB concentration is unknown, except for circuit breakers, reclosers and cable. |
B005 |
PCB articles, other than transformers, that contain 500 ppm or greater of PCBs, excluding small capacitors. |
B006 |
PCB transformers. "PCB transformers" means any transformer that contains 500 ppm PCB or greater. |
B007 |
Other PCB wastes including contaminated soil, solids, sludges, clothing, rags and dredge material. |
Oregon |
|
ORX002 |
Polychlorinated biphenyls (PCBs) |
Pennsylvania |
|
502 |
PCB containing waste |
Rhode Island |
|
R007 |
PCB Waste |
Vermont |
|
VT01 |
Waste containing PCBs in concentrations equal or greater than 20 parts per million |
Washington |
|
WPCB |
Washington State Dangerous PCB Waste containing polychlorinated biphenyls at concentrations of 2 parts per million or greater from specific sources: discarded transformers, capacitors or bushings containing PCBs (except when drained of all free flowing liquid) and the following wastes generated from salvaging, rebuilding, or discarding of transformers, capacitors or bushings containing PCBs at concentrations of 2 parts per million or greater: cooling and insulating fluids and cores, including core papers. |
4. If a waste contains non-TSCA regulated PCBs, does this need to be stated on the manifest?
Yes. If the waste contains PCBs but is not TSCA-regulated waste, it needs to be clearly stated on the manifest, e.g. “Non-TSCA PCB waste.” Using the phrase “Non-DOT Regulated Polychlorinated Biphenyls” is not sufficient to communicate that a waste is not TSCA-regulated. Also refer to FAQ #16 under Receiving Facilities.
5. What information about PCB waste is required to be included on the manifest?
Generators who transport or offer for transport TSCA-regulated PCB waste must include all of the required information on either the manifest (Form 8700-22) or the manifest continuation sheet (Form 8700-22A or other PCB manifest continuation sheet).
The following information is required under 40 CFR section 761.207(a) for each PCB waste category at the specified frequency.
Required Frequency |
Identity/type of PCB waste |
Date of removal from service |
Weight in kilograms |
Unique identifying number |
|
Bulk PCB waste |
Per load |
X |
X |
X |
|
PCB Article Container |
Per container |
X |
X |
X |
X |
PCB Container |
Per container |
X |
X |
X |
X |
PCB Article not in a PCB Container or PCB Article Container |
Per article |
X |
X |
X |
6. Is a Unique Identifier required for every container listed on the manifest?
Yes. A unique identifier is required for each PCB container shipped on a manifest. Refer to the table above for the required frequency and information for each waste type. These requirements can be found at 40 CFR section 761.207(a):
“…The generator shall specify: …For each PCB Article Container or PCB Container, the unique identifying number, type of PCB waste (e.g., soil, debris, small capacitors), earliest date of removal from service for disposal and weight in kilograms of the PCB waste contained. (Item 14—Special Handling Instructions box)”
The generator can choose to assign the manifest tracking number as the unique identifier for a single PCB article or container. For manifests shipping multiple PCB articles and/or containers, the generator can choose to assign Unique Identifiers that include the manifest tracking number, if each item has a unique identifier (e.g., 1234567MTN-01, 1234567MTN-02, 1234567MTN-03).
7. What PCB manifest information is required to be submitted to EPA’s e-Manifest system? If a continuation sheet is used, must it be submitted to EPA’s e-Manifest system?
Facilities receiving PCB waste that is required under either federal or state law to be shipped on a manifest must submit the manifest Form 8700-22, and all required manifest information to EPA’s e-Manifest system. If a continuation sheet is used with the manifest, it must be submitted to EPA’s e-Manifest system. Generators may use Form 8700-22A or other PCB manifest continuation sheet in accordance with Note 1 to 40 CFR section 761.207(a):
“EPA Form 8700– 22A is not required as the PCB manifest continuation sheet. In practice, form 8700–22A does not have adequate space to list required PCB-specific information for several PCB articles. However, if form 8700–22A fits the needs of the user community, the form is permissible.”
8. If a manifest lists waste containing “< 50 ppm PCBs” or “trace PCBs,” is it considered a TSCA-regulated PCB waste that requires submittal of all of the supporting information?
Yes. EPA considers all wastes described as containing PCBs on a manifest to be TSCA-regulated PCB waste and will therefore need the required supporting information. EPA must make this assumption as waste containing < 50 ppm PCBs is often TSCA-regulated, for example, if it is < 50 ppm as a result of dilution. Refer to 40 CFR section 761.60(g) for an example.
If the PCB-containing waste is not required to be manifested under either federal or state law (and thus use of the manifest is voluntary), receiving facilities do not need to submit the manifest to EPA. (Note that any manifest submitted to the EPA, voluntary or otherwise, will incur a user fee.)
In the event that a manifest is not required by the PCB regulations but must be submitted to EPA to fulfill other state or federal regulatory requirements (because, for example, it also includes hazardous waste that must be manifested), the manifest should explicitly say, with respect to the PCB-containing waste, “Non-TSCA PCBs.” This clarification will avoid the receiving facility having to submit any other information about the PCB waste, such as information required under 40 CFR section 761.207.
9. Is it necessary to manifest waste that may or may not be TSCA regulated? I am sending it to the TSDF where they will determine the concentration and regulatory status for me.
Yes. If the regulatory status of the waste has not been determined, you must comply with all of the requirements in 40 CFR part 761 subpart D, including use of a hazardous waste manifest, until such time as the regulatory status is determined. For example, an untested transformer that is shipped as waste without a manifest would be a violation of 40 CFR part 761 subpart K if that transformer was found to contain > 50 ppm PCBs. Since the manifest is required at the time the waste was shipped off-site, the receiving facility is required to submit the manifest to e-Manifest.
Post-delivery, if the waste is determined to be non-TSCA regulated, the receiving facility should follow the necessary steps to resolve the discrepancy, as required by 40 CFR section 761.215. The receiving facility should include the relevant information and a comment in Item 18 of the paper manifest prior to entering the data into the e-Manifest system or correct the relevant waste line information through the e-Manifest corrections process after submitting.