Hazardous Waste Manifest System to Be Streamlined
The Environmental Protection Agency (EPA) proposes to improve the Uniform Hazardous Waste Manifest system by automating procedures and standardizing the manifest form. Waste handlers could realize savings between $24-$37 million a year, and states could save up to 25 percent in manifest-related costs while ensuring the continuous, safe management of hazardous waste.
For more than 15 years, hazardous waste handlers have been required to ship their hazardous wastes according to the Uniform Hazardous Waste Manifest system. The manifest form provides a complete paper trail of a waste's progress from a generator through its treatment, storage, and disposal. The form identifies the type and quantity of the hazardous waste being shipped, the transportation companies that will transport the waste, and the permitted facility that will treat, store, or dispose of the waste. In addition, the manifest form also contains a generator's certification of waste minimization practices.
Whenever a waste handler takes custody of a waste shipment, it must sign the accompanying manifest to acknowledge its receipt and thus create a record of the shipment's chain of custody. When the waste shipment is finally delivered to the permitted facility selected to manage the waste, the receiving facility must sign the manifest, retain a copy as a record, and return a signed copy to the generator who originated the shipment. This closes the accountability circle and enables the generator to verify that the shipment reached its final destination. Either EPA or a state agency must be notified for appropriate action when a generator does not receive a final manifest verification, or when a handler discovers that the shipment actually received does not match the description of the waste on the manifest.
The regulations for generators and transporters in 40 CFR Parts 262-263 are affected by this proposal. Related requirements for owners and operators of treatment, storage, and disposal facilities in Parts 264-265 are also affected, along with state requirements in Part 271.
EPA proposes options to change the Uniform Hazardous Waste Manifest system. Mainly, these changes would allow waste handlers the option of using an electronic manifest to track their waste shipments, and would standardize further the manifest form and procedures.Automation
The proposed rule would enable waste handlers to conduct nearly all the waste tracking and recordkeeping functions of the manifest electronically. The proposal announces standard electronic data interchange and Internet formats that could be used for originating and transmitting the manifest. Under the proposal, the electronic manifest would be signed electronically either with a public key/private key encryption method known as a "digital signature," or with a "secure digitized signature" that uses a digitizer pad and stylus to create a graphic image of a handwritten signature. The proposal also includes computer security controls to protect the integrity of data and to ensure that electronic manifests are processed and stored securely and accurately.
The automation options should significantly reduce the manifest paperwork burden, and should also improve the tracking of hazardous waste shipments. Although waste handlers still may opt to use a paper manifest, the Agency expects that automation will provide better and more timely data on waste shipments for both waste handlers and regulators.Standardization
The Agency intends to eliminate manifest variability by further standardizing the content and appearance of the manifest form. The new standard format announced in the proposal could be used in all states. These proposed changes would eliminate the different manifest forms that are currently required by many authorized states, and also make it possible to obtain forms from a greater number of sources. All manifest forms would be printed according to a precise specification to assure uniformity. Each form would have a unique, preprinted manifest tracking number. Under this option, for example, a waste handler with multistate operations could register and use its own manifest forms everywhere they do business. EPA would oversee the process by which states, waste handlers, or other printers would be registered to print the standard form according to EPA's specifications.Impact
This proposal affects 92,000 businesses in 45 economic sectors that conduct hazardous waste manifest-related activities. These include about 90,000 small and large quantity waste generators, 500 waste transporters, and 2,000 treatment, storage, and disposal facilities in 24 states. Simply automating the manifest form could save up to $27 million a year.