Frequent Questions about e-Manifest
- Receiving Facilities
- Manifest Preparation, Brokers
- Federal and State Implementation
- Fee Obligations
- Record Retention and Distribution
- Data Policy and Data Correction
- System-Specific Questions
- User Registration
*These Frequent Questions were last updated on 6/30/2021
1. 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)?
The e-Manifest Act included a special provision to address this point. Under § 2(h) of the Act, if either the generation state or receiving state requires a manifest during the movement of the waste shipment, then the receiving facility must complete the facility portion of the manifest, sign and date the facility certification to indicate the receipt of the covered wastes (or any discrepancies), and then submit that completed manifest to EPA. The submission of this manifest also requires the receiving facility to pay the associated fee for 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.
2. 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.
3. 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.
4. What documents besides the manifest form and continuation sheets are collected by EPA? For example, does EPA collect the notification associated with the land disposal restriction (LDR) regulations? How does EPA handle any other miscellaneous document it receives?
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.
5. 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 to be shipped under a manifest under either federal or state law, 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.
6. How do the e-Manifest requirements apply to Very Small Quantity Generators (VSQGs) who ship their waste to a Large Quantity Generator (LQG) for consolidation?
In the Generator Improvements Rule, EPA codified a provision 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.
7. Can I use paper manifests after June 30, 2021?
Yes, however, beginning June 30, 2021, EPA will no longer accept mailed paper manifests for processing in the e-Manifest system; after this date, receiving facilities must submit paper manifests either via image upload or data plus image upload to EPA's e-Manifest system. EPA also strongly encourages the use of electronic manifests as these manifests reduce processing burden on facilities and EPA.
8. Can I use old manifest forms after the June 30, 2018, launch of e-Manifest?
EPA is requiring a new 5-copy manifest form on and after the June 30, 2018, launch of e-Manifest. The new 5-copy forms present accurate information on the distribution of the receiving facility copy to the e-Manifest system, and instructions on the use of the manifest. The 5-copy form also removes and consolidates two of the old 6-copy forms, i.e., the two copies marked “Designated facility to consignment state” and “Designated facility to generator state.” These are no longer needed as only one copy is submitted to EPA’s e-Manifest system. States have access to the manifest data through the e-Manifest system.
EPA believes it is important that the manifests convey accurate information on distributing the top copy (Page 1) of the manifest to the EPA system, or otherwise, many forms may be misdirected to the states. Any misdirected forms could cause confusion for our authorized states, and perhaps result in a facility failing to comply with the RCRA requirement to submit copies of all their manifests to e-Manifest and pay the applicable fees.
EPA accepts Page 1 copies of the obsolete 6-copy forms for processing after June 30, 2018, but we strongly recommend that users transition to the 5-copy forms as quickly as possible. If a user wishes to continue to use the obsolete 6-copy forms, they should undertake measures to minimize confusion. For example, one approach (although not a requirement) could include applying a pre-printed adhesive label to the top copy with the accurate copy distribution language ("designated facility to EPA's e-Manifest system"). Facilities should train their manifest personnel to inspect manifests carefully to ensure they are routed properly during the time any of the obsolete manifests remain in use.
Updated June 11, 2018
9. What are the specific changes to the manifest form for use as of June 30, 2018?
The changes to the manifest form effective as of June 30, 2018, are:
- Replacement of the 6-copy manifest with a 5-copy form, resulting from the replacement of two copies that were previously earmarked for distribution to states with one copy to be submitted to the e-Manifest system;
- The copy distribution notation at the bottom of Page 1 requires the receiving facility to submit this copy to the e-Manifest system;
- There is a warning notice to receiving facilities at the bottom of Page 3 advising all such facilities that if they received a waste accompanied by a manifest, they have responsibilities under the e-Manifest Act described in the instructions on the back of the form; and
- The instructions on the back of each copy correspond to the type of handler associated with each manifest copy, and include the new instructions for receiving facilities to submit manifests to the system.
10. 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.
11. 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 40 CFR 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.
12. Does waste containing TSCA-regulated 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. See 40 CFR 761.207 for more information.
13. 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, see 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.
PCB and other material containing PCBs
PCB1 Solids (Capacitors, Transformer Carcasses)
PCB2 Liquids (Transformer and Capacitor Oils, etc.)
PCB Content of 50 ppm of higher
Universal Waste PCB
Polychlorinated biphenyls (greater than 500 ppm)
Polychlorinated biphenyls (50 to 500 ppm)
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
Generic PCB Waste
PCB Oil (concentrated) from transformers, capacitors, etc.
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.
Petroleum oil or other liquid containing 500 ppm or greater of PCBs.
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.
PCB articles, other than transformers, that contain 500 ppm or greater of PCBs, excluding small capacitors.
PCB transformers. "PCB transformers" means any transformer that contains 500 ppm PCB or greater.
Other PCB wastes including contaminated soil, solids, sludges, clothing, rags and dredge material.
Polychlorinated biphenyls (PCBs)
PCB containing waste
Waste containing polychlorinated biphenyls (PCB) in concentrations equal or greater than 20 parts per million
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 polychlorinated biphenyls (PCB) at concentrations of 2 parts per million or greater: cooling and insulating fluids and cores, including core papers.
14. 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. See also FAQ #16 under Receiving Facilities.
15. 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) should not submit their manifests to the e-Manifest 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. These state-specific tracking documents are not RCRA manifests. Therefore, “milk run” or “consolidated” shipments are not subject to e-Manifest requirements and should not be submitted to EPA’s e-Manifest system. The user should follow state law requirements on the disposition of these manifests.
18. Are VSQG/CESQG waste shipments subject to e-Manifest?
This answer depends on the state. In general, Very Small Quantity Generator (VSQG)/Conditionally Exempt Small Quantity Generator (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.
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 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.
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 for e-Manifest if they wish to sign manifests electronically, view and maintain manifest records in the system, or submit post-receipt data corrections to the manifest.
2. How is e-Manifest assisting generators in moving from paper manifests to electronic manifests?
EPA recognizes that generators face several implementation challenges in e-Manifest, particularly, for those generators that ship small quantities of waste or that ship wastes infrequently. Therefore, we have endeavored to develop e-Manifest and the system’s implementing regulations to ease the implementation burden for generators.
EPA has included regulatory incentives to facilitate the participation of generators in e-Manifest.
- First, transporters who act as offerors of their generator customers’ shipments may sign the manifest “on behalf of” the generator if the offeror prepares the shipment and the manifest for the generator and has personal knowledge of the facts underlying the generator/offeror certification.
- Second, the e-Manifest User Fee Rule supports a hybrid manifest approach under which the generator and initial transporter may sign a paper manifest copy, which the generator retains on-site. The initial transporter and subsequent waste handlers then process the remainder of the transaction electronically. Thus, generators can continue to sign in the field and retain a paper copy of their initial manifest just as they have done under the existing manifest system. However, they still need to register with e-Manifest and create an account to view their manifest copies when they are signed and submitted as final manifests by the receiving facility, or, they need to make special arrangements with the receiving facility to obtain a signed paper copy from the facility.
- Third, EPA has removed the requirement for generators, transporters and the initial signature at the receiving facility to use Cross-Media Electronic Reporting Rule (CROMERR)- complaint electronic signatures. Users with at least preparer permission level can now use the “Quick Sign” feature (CROMERR compliant signatures, however, are still required when a receiving facility submits the final electronic manifest).
- Another example of regulatory incentives is the manifest data corrections process included in the final user fee rule of January 3, 2018. See 40 CFR 262.24(h). While generators may elect to continue to use paper manifests (or the hybrid) for delivering their wastes to the initial transporter and/or tracking their shipments to designated receiving facilities, manifest data corrections are handled in e-Manifest by an exclusively electronic process. In order to participate in the manifest data corrections process, generators need to establish an account in e-Manifest where they can view their final copies signed by receiving facilities. In addition, this account is where generators receive any notices related to later data corrections made by interested waste handlers or regulators, and where they may themselves submit certified corrections of data to the system.
EPA notes that there are other provisions in the e-Manifest regulations that will create incentives for generators to become more involved with electronic manifesting. The hybrid manifest authorized under 40 CFR 262.24(c)(1) is one such example. By aligning with a service company that participates in electronic manifesting, but that allows the generator to retain a paper copy under the hybrid approach, generators will have relationships with entities that are supporting and promoting electronic manifesting. In time, EPA expects that the activities of these service companies will foster more participation by generators in electronic manifesting, and that the service companies will make an effort to transition their generator customers from the hybrid to the fully electronic manifest.
3. What is a hybrid manifest? How does it help generators use e-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.
4. Are generators given a paper copy of the manifest form under the hybrid manifest (which is signed electronically by the transporter)?
Under the hybrid manifest approach, generators are given a paper copy that is signed, by hand, by the generator and the initial transporter. The generator retains this signed paper copy as their initial manifest copy, just as they have done under the existing manifest regulations for paper manifests. The transporter and subsequent waste handlers then conduct the remaining manifest completion and tracking requirements electronically in the system. Generators that utilize hybrid manifest are also given paper copies of completed manifests from receiving facilities.
5. 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.
6. 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. Beginning June 30, 2021, receiving facilities must submit paper manifests as either a scanned image upload or a data plus image upload (of course, when generators sign electronic manifests in e-Manifest, these records are accessible in the e-Manifest system).
7. 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.
8. How many ways are there for generators or offerors to initiate a manifest in the e-Manifest system?
A generator or offeror can initiate a manifest in one of three ways: (1) using the paper manifest, with “by hand” signatures being executed by all handlers throughout the process; (2) using the electronic manifest, with electronic signatures being executed by all handlers throughout the process; and (3) using the “hybrid” manifest, in which a manifest is created as an electronic manifest in e-Manifest but then printed out and signed by the generator and initial transporter and then retained at the generator site. The initial transporter and other handlers complete the hybrid manifest electronically.
9. 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 if a generator can electronically sign in RCRAInfo. 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).
10. 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 electronic manifest users, all manifest copies are available in the system for viewing and inspection.
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.
Also, under the federal manifest regulations, the generator’s initial paper copy may be discarded and replaced by the final manifest copy when returned to the generator by the receiving facility. Thus, registered generators can use e-Manifest to meet their recordkeeping requirements with respect to the image file copy of the final manifest, and can also discard any corresponding paper copy of the initial manifest, 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. Thus, it must be retained for completeness. 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.
11. Does the requirement under 40 CFR 262.24(a)(3) that generators' manifest records in the e-Manifest system be "readily available" for viewing and production for RCRA inspectors mean that the generators have already registered with the e-Manifest system?
Yes. This provision of the e-Manifest regulations applies to generators that are using electronic manifests and accessing manifest records in e-Manifest. A generator must be registered with e-Manifest in order to do both.
12. 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.
13. How does e-Manifest affect Exception Reporting by generators?
Exception reporting requirements (40 CFR 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.
14. 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 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. See 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.
15. 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, as discussed above, the temporary or provisional nature of the site may suggest the use of a paper manifest or hybrid manifest for their shipments, as an EPA ID number is not required as part of the generator information to be entered on the paper form. If it is desired to use fully electronic manifests, then these sites must obtain an EPA ID before completing any electronic manifests. EPA does encourage the use of electronic manifests, however, and in those cases where an electronic manifest is desired, these facilities can obtain an EPA ID Number by filing EPA Form 8700-12 with the EPA Region or authorized state.
16. Are facilities that have ID Numbers, but that are not in RCRAInfo, subject to e-Manifest?
These facilities are subject to e-Manifest if the shipment to and from such facilities requires a RCRA manifest under either federal or state law.
Facilities that file the Site ID Form are issued an EPA ID Number, and this number is automatically added to RCRA Info and is available in the system’s look-up tables for use in completing electronic manifests.
Facilities with state ID numbers that are not EPA ID numbers in RCRAInfo will not be able to complete electronic manifests until these ID numbers have been manually added to RCRAInfo. Until this occurs, the facility should complete paper manifests that include its State ID Number in the appropriate field of the paper manifest. Electronic manifests cannot be used if the facility’s ID Number cannot be found in RCRAInfo and the system’s look-up table. We encourage you to contact your state regarding specific questions on such state-issued IDs.
Additionally, for state waste receiving facilities that are new to RCRAInfo and e-Manifest, please coordinate with your Regional and State contacts to ensure that your ID number is recognized in the system as a receiving facility. A list of EPA Regional contact is available here.
17. 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 761.207(a) for each PCB waste category at the specified frequency.
Identity/type of PCB waste
Date of removal from service
Weight in kilograms
Unique identifying number
Bulk PCB waste
PCB Article Container
PCB Article not in a PCB Container or PCB Article Container
18. 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. See the table above for the required frequency and information for each waste type. These requirements can be found at 40 CFR 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)”
19. Can I use the manifest tracking number as the Unique Identifier?
Yes. 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).
20. Must a generator keep a distinct paper copy of the manifest available for DOT inspectors that inspect the generator site?
No. Copies of manifests in e-Manifest satisfy the DOT’s hazardous materials regulations on retention of shipping paper records. The DOT rules allow shippers (generators) to retain copies of shipping papers such as the manifest electronically, although they may be asked to produce a hard copy of the electronic document on the request of the inspector. This is also a requirement for RCRA inspectors.
21. 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, in some authorized states, the states have elected to require manifests for VSQG/CESQG wastes. Additionally, federal rules require manifests for certain episodic waste events at VSQGs, 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 generator 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.)
22. How many waste codes must be entered on electronic manifests?
The regulatory requirements for entering waste codes have not changed, 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.
23. What is required on the manifest for shipment of non-creditable hazardous waste pharmaceuticals?
For more information see: Frequent Questions about Manifesting Non-creditable Hazardous Waste Pharmaceuticals
1. What options do hazardous waste handlers have for submitting manifests to the e-Manifest system?
Receiving facilities have several 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.
The sunset date for mailing the manifest form to the e-Manifest system is June 30, 2021. After this date, only the digital methods of paper copy submission will be available to receiving facilities.
2. How will EPA manage paper manifests that are mailed to the e-Manifest paper processing center after June 30, 2021?
Paper manifests mailed to EPA after June 30, 2021, will not be accepted by EPA. EPA will return to the sender any manifests and continuation sheets that are mailed to the e-Manifest paper processing center after this date.
Per 40 CFR 264/265.71(a)(2)(v)(B), beginning June 30, 2021, receiving facilities must ensure they submit any paper manifests by either uploading an image of the paper manifest (image upload) or uploading a data file plus image copy of the paper manifest (data plus image upload) to ensure compliance with EPA’s requirement to submit paper manifests within 30 days of receipt of the shipment.
If receiving facilities receive an error while submitting a paper manifest (e.g., scanned image upload or data plus image upload) to the e-Manifest system, please use the Feedback/Report an Issue option in RCRAInfo to submit a ticket with the error received and any relevant information.
3. How soon after receiving a shipment do I need to sign for that shipment? Is there anything different if I sign electronically versus on paper?
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.
4. How soon after completing a manifest do I need to submit that manifest to EPA?
The regulations for paper manifest submissions specify that a completed manifest must be submitted to the EPA’s e-Manifest system within 30 days of the delivery of the waste to the receiving facility. This 30-day timeframe extends to submission of paper manifests by scanned image upload or data plus image upload. Electronic manifests, of course, are created, transmitted and signed in the e-Manifest system, and thus are submitted at the time the receiving facility signs electronically for the receipt of the wastes.
5. Whose responsibility is it to submit manifests to EPA?
Receiving facilities are responsible for submitting manifests and paying the applicable per manifest fee to EPA. The responsibility for paying the per manifest fee for electronic manifests belongs to the receiving facilities designated on the manifests and accrues when the receiving facilities submit the final signed manifest to the system.
6. Do the requirements in 40 CFR 264/265.71(a) describing how a receiving facility must manually sign manifests and distribute copies to the transporter and the generator only apply to paper manifests? Would the wording in 40 CFR 264/265.71(a)(2) regarding signing and dating “by hand,” still apply with an electronic signature?
The manifest regulations addressing how receiving facilities execute manifests generally describe the requirements for facilities to sign and submit manifests when they receive hazardous waste shipments accompanied by a manifest. These regulations further require the facility to sign and date the manifest by hand to indicate receipt or shipment discrepancies, then give a copy to the delivering transporter, and then, within 30 days, return a copy to the generator.
While these requirements describe the mechanics of processing a paper manifest, they are also relevant to electronic manifests. Under the 2014 One Year Rule, EPA determined that an electronic manifest that is obtained from e-Manifest, signed electronically and submitted to the system in accordance with the rule’s conditions are the legal equivalent to a paper manifest processed in the conventional way. So, while the person signing an electronic manifest per the rule may not sign “by hand” as is done with paper manifests, if they follow the requirements in the e-Manifest rules for obtaining, completing, and submitting electronic manifests, they have done the functional equivalent of signing a manifest by hand, and the electronic manifest is as valid as a paper manifest.
7. I am a TSDF that accepts wastes from states other than my own. If a waste’s originating state requires a manifest for a waste that my state does not require, must I register and submit a manifest to the e-Manifest system?
Yes, per the e-Manifest Act, if the waste has a manifesting requirement under the law of either the origination (generator) state or the destination state, then the receiving facility must submit the manifest to the system and pay any applicable fees associated with that manifest.
8. 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 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.”
9. 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. If there is a registered e-Manifest user (meaning someone who can download a copy of the manifest), the system will show “Yes,” as illustrated below. In addition, 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).
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.
10. 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.
11. Can receivers opt out of the e-Manifest requirements by using a paper manifest?
No. All receiving facilities must submit all manifests they receive (whether paper or electronic) to EPA’s e-Manifest system and pay applicable user fees as required. Using a paper manifest enables a user to opt out of the electronic manifest, but still requires a manifest submission and a timely fee payment on the part of the receiving facility.
12. 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.
13. 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 in the manner discussed above 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.
14. 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.
15. 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. See 40 CFR 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 761.207.
16. 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.
17. Can authorized states still require that a Discrepancy Report letter be sent to the states when a paper manifest discloses an unreconciled significant discrepancy?
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.
18. 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.
19. When rejected 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?
The hazardous waste rejection regulations for full or partial returns of rejected shipments to the generator require generators to sign Item 18c of the manifest, if the receiving facility returned the shipment using the original manifest. Alternatively, if the receiving facility returned the shipment using a new manifest, the generator would sign Item 20 of the manifest. Because Item 19 is customarily completed by the receiving facility, the generator must also complete Item 19. 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 (See 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 262.16 (small quantity generators) or 40 CFR 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.
1. Can a highway transporter’s electronic signature be executed by a person other than the transporter’s representative who is present at the generator site for the waste pick-up?
No. When an electronic manifest is used for highway mode of hazardous waste transportation, the transporter’s representative that is present at the generator site for the waste pick-up is the only person that can sign the manifest electronically to acknowledge receipt of the materials from the generator for transportation. This is typically the driver of the transport vehicle. The transporter representative present at the generator site plays a valuable role in verifying that the materials described on the manifest as being shipped by the generator are in fact properly described on the manifest, are properly packaged and labeled, and are in proper condition for transportation.
For rail transportation, there are other requirements and considerations that apply so that company officials or other persons may sign manifests to acknowledge receipt of waste shipments by a rail transporter. Manifests are not normally carried on the rail equipment, and the crew members operating trains are not typically in a position to sign the manifest.
2. Can the generator sign a manifest on behalf of a highway transporter?
No. The driver or other transporter representative that is present at the generator site for the waste pick-up is the only person that can sign the manifest to acknowledge receipt of materials from the generator for highway transportation. 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. States are generally required by authorization deadlines (see 40 CFR 271.21(e)) to make program modifications within one year from the time EPA issues a new RCRA regulation. What if more time is required for states to implement e-Manifest requirements?
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.
EPA recognizes that state progress in adopting program changes such as e-Manifest can be affected by many factors. Nevertheless, EPA believes that e-Manifest brings helpful changes to the manifest program that make state compliance and tracking programs much more efficient once e-Manifest related changes are adopted by the states. Therefore, we encourage states to adopt the changes included in the One Year Rule and the User Fee Rule at their earliest convenience, so that the states may share in the innovations and efficiencies.
Until such time as the states adopt the necessary regulatory changes, the Act provides that EPA will implement and enforce the e-Manifest program consistently in all the states. Thus, states that need more time to make these changes can take additional time to adopt e-Manifest requirements, and the program will still be implemented in the state by EPA. However, states will not be able to fully implement the e-Manifest regulatory program until they adopt the necessary program changes and obtain authorization from EPA.
3. 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 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.
4. Do I have to wait for my state to adopt the e-Manifest rules before using the e-Manifest system?
No. When the Congress authorized the creation of an e-Manifest system, it provided that e-Manifest would go into effect federally in all states on the system launch date determined by EPA, regardless of any state's rule adoption or authorization status. EPA launched e-Manifest on June 30, 2018, which coincides with the effective date of the e-Manifest rules. Thereafter, as states adopt state law counterparts to EPA's e-Manifest requirements and obtain program authorization from EPA, the states may assume implementation and enforcement responsibilities for those parts of the e-Manifest program that are delegable to states.
5. 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, as EPA does not collect and process the generator and transporter copies of paper manifests in e-Manifest. This includes generator copies of any paper manifest signed by the generator, including hybrid manifests where the generator signs on paper. However, after e-Manifest launched on June 30, 2018, the receiving facility copies of manifests may only be collected by e-Manifest, and not directly by the states. States can obtain their receiving facility data from the e-Manifest system rather than from the facilities. 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.
6. When will states have access to the e-Manifest data once submitted?
States with connectivity to the e-Manifest system have immediate access to all manifests for which the state is shown as either the generation state or the destination state.
7. 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.
Beginning June 30, 2021, receiving facilities have two options for submitting paper manifest to the e-Manifest system; as a scanned image upload, or data plus image upload.
8. 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. This is because the generator has signed electronically in the system and thus states can receive their manifest copy from e-Manifest. This is consistent with Congress’ objective that e-Manifest reduce paperwork burdens by establishing e-Manifest as a national reporting hub for collecting and distributing manifests.
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.
9. How will use of e-Manifest relate to the Department of Transportation (DOT) hazardous material regulations (HMR) requirement to use a shipping paper?
EPA is coordinating with DOT during the development of e-Manifest. The system will generally allow a user to produce a manifest that satisfies the DOT HMR requirement for a shipping paper. One key point is that DOT currently requires that a hard copy shipping paper be placed in the cab of the transport vehicle during transportation. Therefore, handlers using e-Manifest will still need to comply with that requirement (e.g., print the manifest from the e-Manifest system).
10. 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.
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. The per manifest fees under the User Fee Rule vary based on the type of manifest (paper or electronic) and the manner of submission (e.g., data plus image upload, scanned image upload). EPA does not impose fees on generators or on members of the pubic that would use the system only to access data.
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 that interested persons may submit at 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. EPA's program-related costs include the Agency's intramural and extramural costs in establishing and operating the e-Manifest system, including the costs of developing the program's implementing regulations, as well as the costs related to managing the program.
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 firstname.lastname@example.org.
7. What if the system goes down while I am trying to update or correct manifest data?
There are no adverse consequences should the system go down while submitting a data update or correction. There is no time limit on when data corrections may be submitted to e-Manifest, nor are there fees charged for any data corrections. So, if the user submitting the correction should find that their previously attempted correction was not entered in the system records, he or she should re-submit that correction when the system is again available.
8. What are the final user fees that EPA charges users to use the system?
EPA charges user fees for each manifest submitted to the system. The user fees are updated every two years and are set based on manifest usage and processing cost for each manifest type. You can find the current e-Manifest User Fees and Payment Information here.
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 becomes an electronic manifest in e-Manifest? 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. 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.
4. 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.
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 last correction made with respect to a manifest is regarded as the final and correct representation of the data, unless a later notice is received. 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. See 40 CFR 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. Does EPA prioritize processing of certain manifests over others?
No. Once EPA has established that a submitted document is a valid manifest submission eligible for inclusion in e-Manifest, there are no priority in the processing of manifests. Manifests including federal RCRA wastes have the same priority as manifests involving state-only regulated wastes that require a manifest under state law.
EPA acknowledges, however, that in early implementation of e-Manifest, there may be a lag in processing time for certain paper manifests, such as paper that require processing.
4. 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.
5. 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.
6. 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.
7. In 40 CFR 265.71 (l) there is a statement that corrections can be made by interested parties at any time; what version of the manifest will be used in an enforcement case?
Both the final copy of the manifest signed by the receiving facility and corrections introduced later by the corrections process may have relevance. The 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 as to the materials listed on the manifest and understood at that time as having been received. The system retains the manifest copy as signed by the receiving facility as the copy of record of the manifest at waste receipt, and the data from this signed manifest is the source of the data for the data record in the system for that shipment. In most instances, that is the first and last information reported to the system on the receipts for that shipment.
However, there is a data corrections process, whereby facilities and other waste handlers may enter certified corrections to the waste receipt data, when an error is discovered post-receipt in the data system. Such a correction might occur when either the signed manifest is itself found to be in error on closer examination of the shipment contents, or, when an error was made in entering information from the original paper manifest into the system. 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. The use of the corrections process facilitates data quality in the manifest data system, particularly, as we move toward integrating the system with the biennial reporting process.
8. Is the e-Manifest system linked to RCRAInfo?
Yes, e-Manifest is linked to RCRAInfo and 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.
9. 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.
10. After a manifest has been signed and submitted in the e-Manifest system and the generator decides that a correction to the information in e-Manifest is necessary and enters the correction, does the receiving facility need to re-sign that manifest?
No. A post-receipt correction operates as a change to the data records in the e-Manifest system but does not require the original manifest to be altered or re-signed by a receiving facility. (Note, though, that the handler submitting a correction to the manifest record must electronically sign that correction.)
11. 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.
12. 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 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.
13. 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.
14. 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.” See 40 CFR 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. See 40 CFR 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.
1. Is e-Manifest accessible on mobile devices, like a tablet or smart phone?
Yes, e-Manifest is accessible on mobile devices.
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?
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, signed manifest to EPA or to users (e.g., generators, transporters, and receiving facilities) submitting post-receipt corrections to the e-Manifest system. One key difference between the two signature methods is Quick Sign only requires users to click the “Quick Sign” button to electronically sign. Unlike the Quick Sign signature method, the CROMERR-compliant signature method requires users to enter their login information and answer a challenge question in order 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.
5. Will users who already have Certifier or Site Manager permissions be able to use Quick Sign?
Yes. Users who have Certifier or Site Manager permissions have access to Quick Sign as well as the traditional CROMERR-compliant signature method. (Note that receiving facilities submitting the final, signed manifest to EPA or users submitting post-receipt corrections to the e-Manifest system, must use the CROMERR-compliant signature method).
6. Do users need to log in to use the Quick Sign button?
Yes. Users who wish to electronically sign using Quick Sign must have previously registered, been granted site permissions, and be logged into e-Manifest when signing.
7. 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.
8. I have over 100 manifests to upload. Do I have to sign each one separately?
Whether using the web application or submitting via services, you will need to upload each manifest individually. However, you can choose to save the manifest, thereby placing the manifest in a queue. When you return to your “Manifest Dashboard,” you will see the “Sign Manifests” option. Here you can select multiple manifests to sign with a single signature process. Starting January 2021, the system will allow bulk signature of 500 manifests; this number may increase in the future.
9. I requested a new Site EPA ID and was approved. How do I begin participating in e-Manifest?
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.
10. If there are more than four line items, does the system create a continuation sheet?
11. If drivers do not carry mobile devices, how do they sign electronically?
If the driver otherwise has access to a computer or smart phone, they can sign electronically in EPA’s e-Manifest system. If not, they would not be able to sign electronically and, instead, must sign on paper.
12. 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.
13. Are automated notifications generated if manifests are pending for signature?
Not at this time, this is future functionality.
14. 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.
15. Are state hazardous waste codes included in e-Manifest (in addition to federal hazardous waste codes)?
Yes. States have provided this information to EPA and it is available in the system.
16. Can you use an application interface (API) to sign manifests?
Not at this time. APIs are available to push and pull data on manifest(s) but electronic signatures must be performed in the e-Manifest system.
The system provides a set of UI Link services that allows systems to send their users directly to the manifest(s) they need to sign. 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.
17. 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.
18. Can a user create and save a template in e-Manifest? For example, for repeat shipments? In other words, will e-Manifest allow me to create several manifests with the same information at one time or will I need to create them individually?
Yes, users can simply use the copy manifest icon on the e-Manifest dashboard.
19. 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.
20. Does the e-Manifest system meet the American Disabilities Act Standards for accessible design?
Yes, e-Manifest meets the American Disabilities Act standards (also known as “508 compliance”).
21. If a receiving facility is using a data upload to submit a manifest, how are the manifest numbers generated?
This depends on how the manifest is created. If the manifest is paper and created on a 5-copy paper manifest then the receiving facility provides the manifest tracking number from the paper form. If the manifest is created as a fully electronic or hybrid manifest, EPA creates the manifest tracking number in e-Manifest and returns it to the receiving facility.
22. Can states see attachments/images in e-Manifest?
23. How does e-Manifest handle multiple handling codes for a single manifest line item, e.g., for lab packs?
A company may include as many waste codes as they need on each waste line.
24. 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.
25. 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.
26. Can you sign paper manifests once the manifest has gone electronic? For example, if a generator or transporter has signed electronically, can the receiving facility sign on paper?
No. Once a generator or initial transporter (under the hybrid manifest approach) signs electronically, all subsequent entities must sign electronically.
27. Can states extract metadata from e-Manifest?
Yes, states can extract metadata from e-Manifest via RCRAInfo, the RCRA Node, and the e-Manifest services. Metadata that a state can extract from e-Manifest include; created date, last updated date, whether the site has notified with the state, whether their site information was modified from what is recorded in RCRAInfo, electronic signature information, and the printed document information, including file size.
28. Does e-Manifest allow use of decimals in the quantity field?
No, the current paper manifest system does not allow for decimals.
29. Will e-Manifest allow for printing of hazardous waste labels?
30. 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.
31. 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.
32. 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 see 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 see a blank field.
- You will now be required to access your email account and locate an email message from email@example.com.
- 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.
33. I’m a generator/transporter, how do I view my paper manifests in e-Manifest?
Log in to your RCRAInfo Industry account. Then enter your EPA ID number (as listed on the paper manifest) into the e-Manifest module. You will be able to see all manifests associated with your EPA ID number.
34. 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!
1. Does each person need to register for e-Manifest? Or can there be one company account shared by multiple users?
Yes, each person needs their own account to create and sign manifests.
2. What is the current user registration process for e-Manifest?
You must register to become a user of the e-Manifest module in EPA’s RCRAInfo system. Please refer to Step 3: Register for e-Manifest in RCRAInfo under "How to Register for e-Manifest" for further information.
3. Does EPA charge a fee for registering?
No, EPA does not charge a fee for registering with e-Manifest.
4. I’m registered on the RCRAInfo test site, do I need to re-register in RCRAInfo to participate in e-Manifest?
Yes. User testing participants 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. Therefore, you must re-register in the RCRAInfo (production) system for access to the e-Manifest module. 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 for myRCRAid/Biennial Report, 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).
The user registration process is the same for all modules in RCRAInfo. The registration process for BR, e-Manifest, and myRCRAid are based on the account registration process used for EPA's Central Data Exchange (CDX). The user accounts may be used within CDX and existing CDX accounts may be used within RCRAInfo. To use an existing CDX account, enter your CDX credentials in the RCRAInfo Sign In 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|
|Create manifests, edit Draft manifests, and complete non-CROMERR compliant signatures.||
|Complete CROMERR compliant signatures, correct manifest data electronically, and submit manifests.||
|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.||
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. 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.
12. 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 (e.g., someone who can pay user fees).
13. 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.
14. 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.
15. 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.
16. 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.)
17. 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.
18. I’m a state user of RCRAInfo, do I need to re-register for access to e-Manifest?
No, you are able to access manifests and reports via the e-Manifest module in RCRAInfo. For state users that wish to correct manifests, you will need to request the e-Manifest Maintenance role be added to your account.
19. What states have opted in to myRCRAid or Biennial Report (and thus are where states may begin registering users as a Site Manager)?
The following states and territories have, as of November 18, 2020, opted in to one of the available RCRAInfo industry applications, i.e., myRCRAid and Biennial Report. Entities within the below states and territories may begin registering Site Managers for their site. (EPA will update this list periodically.)
If your state or territory does not appear on the below list, you are unable to register as a Site Manager at this time. EPA anticipates being ready to accept registrations for e-Manifest, which will be available for all states and territories, in Spring 2018.
Alaska (BR, myRCRAid)
American Samoa (BR, myRCRAid)
Arkansas (BR, myRCRAid)
California (BR, myRCRAid)
Colorado (BR, myRCRAid)
Connecticut (BR, myRCRAid)
Delaware (BR, myRCRAid)
District of Columbia (BR, myRCRAid)
Georgia (BR, myRCRAid)
Guam (BR, myRCRAid)
Hawaii (BR, myRCRAid)
Maine (BR, myRCRAid)
Maryland (BR, myRCRAid)
Massachusetts (BR, myRCRAid)
Montana (BR, myRCRAid)
Navajo Nations (BR, myRCRAid)
Nebraska (BR, myRCRAid)
Nevada (BR, myRCRAid)
New Hampshire (BR)
New Jersey (BR, myRCRAid)
New Mexico (BR, myRCRAid)
New York (myRCRAid)
North Carolina (BR, myRCRAid)
North Dakota (BR, myRCRAid)
Northern Marianas (BR, myRCRAid)
Oklahoma (BR, myRCRAid)
Puerto Rico (BR, myRCRAid)
Rhode Island (BR, myRCRAid)
South Dakota (BR, myRCRAid)
Trust Territories (BR, myRCRAid)
Utah (BR, myRCRAid)
Vermont (BR, myRCRAid)
Virgin Islands (BR, myRCRAid)
Virginia (BR, myRCRAid)
West Virginia (BR, myRCRAid)
20. Does the transporter need to register individual drivers in order to sign electronically?
21. 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.
22. If I create an e-Manifest account, can multiple persons use it to sign electronic manifests?
No. Each person involved in preparing, certifying, or viewing manifests on behalf of a regulated waste handler must have an individual account specific to their user permission (preparing, viewing, certifying) to conduct manifest activities for the regulated entity. In addition, each certifier that electronically signs manifests must have unique electronic signature credentials. The Site Manager for each facility can assist a facility’s users in setting up their individual accounts and granting them the necessary permissions to participate in e-Manifest.
1. Who should I contact if I have questions about my invoice?
If you have any issues with your invoice, contact firstname.lastname@example.org 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.
Site Managers looking to pay their invoice can do so in e-Manifest by clicking on the “Pay Bill” button. This will pull up a popup window that will allow you to make payments to Pay.Gov directly; previous guidance stated you would need to register for an additional account with pay.gov, but this is no longer the case. 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. Thus, a separate account with Pay.Gov is not required. The invoicing and electronic 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 email@example.com 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 firstname.lastname@example.org. 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 email@example.com.
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 see EPA’s Fact Sheets for e-Manifest stakeholders 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 firstname.lastname@example.org.
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 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 email@example.com.