Frequent Questions about e-Manifest
EPA recently decided to grant extra time for receiving facilities to submit paper manifests during the initial months after system launch. For more information on this, please read the FQ below.
- 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
- 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 will also require 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 will enable 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. Will e-Manifest include imported waste shipped on a manifest? Will it include exported waste shipped on a manifest?
The e-Manifest system will track 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 U.S., their tracking is not that different than any other domestic waste shipment.
However, during this initial phase of implementation, the e-Manifest system will not track export manifests. Initially, the e-Manifest system’s manifest submission and fee collection requirements will be focused on the receiving facilities in the U.S. 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, EPA will need to work out how and when the exporters or other entities involved with export shipments can supply these export manifests to the system and pay the requisite processing fee. It may require another rulemaking to sort out these issues, and until further notice, the system will not collect export manifests.
- 4. Will EPA be collecting any other documents besides the manifest form and continuation sheets? For example, will EPA collect the notification associated with the land disposal restriction (LDR) regulations? How will EPA handle any other miscellaneous document it receives?
The initial e-Manifest system will focus 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 will not process LDR notices or any other non-manifest documents. We will also not process export manifests in the initial system. EPA will recycle any miscellaneous documents it receives.
- 5. What manifests must be 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?
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.
- 6. Will 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 recently promulgated 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, 2018?
Yes. Under the e-Manifest Act and EPA's implementing regulations, manifest users may continue to use paper manifests after the system launches on June 30, 2018. However, EPA strongly encourages the use of electronic manifests as these manifests will be the least expensive and easiest way to comply with the regulations.
- 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 will be submitted to EPA’s e-Manifest system. States will then 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 will accept 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 after June 30, 2018?
The changes to the manifest form that will be required to be used after 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 will require the receiving facility to submit this copy to the e-Manifest system;
- There is a new 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 will 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 will thus be 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. Will 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 will collect 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.
- 12. Will the data elements currently applicable to paper manifests change with the use of electronic manifests?
No, the basic regulations or instructions for completing an electronic manifest will not be materially different from today's regulations or instructions for completing a paper manifest. The data elements will 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.
- 1. Do generators have to register for e-Manifest?
It is not required that generators register for e-Manifest by June 30, 2018. 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.
Eventually, and over time, generators will need to register for e-Manifest if they wish to sign manifests electronically in the system, view manifest records in the system, or if they want the ability to submit post-receipt data corrections to the manifest.
- 2. How will e-Manifest assist 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 other 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 as the offeror “on behalf of” the generator if the offeror prepares the shipment and the manifest for the generator customer 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 and retain it 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 will still need to register with e-Manifest and create an account where they can view their manifest copies when they are signed and submitted as final manifests by the receiving facility, or, they will need to make special arrangements with the receiving facility to obtain a signed paper copy from the facility.
Finally, 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.
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 will be handled in e-Manifest by an exclusively electronic process. In order to participate in the manifest data corrections process, generators will 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 will 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. By creating and using these e-Manifest accounts to view manifest copies, view correction notices, and make their own corrections, generators may become more acquainted and comfortable with electronic services, and in particular, with using an electronic certification of their corrections. This will provide a good foundation for completing electronic manifests and for signing manifests electronically when they are ready to participate more fully in electronic manifesting.
- 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 will 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. Will generators be 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 will be given a paper copy that will be signed by hand by the generator and the initial transporter. These generators will retain 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 will conduct the remaining manifest completion and tracking requirements electronically in the system.
- 5. How will 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 will only supply 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 will only collect paper manifests from the receiving facility. (Of course, when electronic manifests are signed by generators in e-Manifest, these records will be accessible in the e-Manifest system.)
- 1. Can EPA provide additional time for receiving facilities to submit manifests and ease the burden of transitioning to the new e-Manifest system?
Yes. EPA recently decided to grant extra time for receiving facilities to submit paper manifests during the initial months after system launch. Under EPA’s regulations, receiving facilities must submit paper manifests to EPA within 30 days of receipt. However, EPA will allow receiving facilities to submit paper manifests they receive between June 30, 2018, and September 1, 2018, by September 30, 2018. This effectively provides receiving facilities up to 60 additional days, over the existing 30 days provided in the regulations, to submit paper manifests to EPA.
This does not change the requirement for receiving facilities to send manifests initiated on and after June 30, 2018, to EPA and for EPA to then charge a user fee for each manifest it receives. Rather, it simply extends the deadline for when paper manifests would be due to EPA. There are three ways for receiving facilities to submit a paper manifest: (1) through the U.S. mail; (2) upload of a scanned image of the manifest; and (3) sending a data file plus a scanned image of the manifest. Once the paper manifest is received by EPA, EPA will charge a user fee for each manifest based on how the manifest was submitted and the corresponding costs to EPA to process the data. EPA charges the highest user fee for paper manifests mailed to the Agency, a lower fee for uploads of scanned images, and a lower fee still for manifests submitted as data files plus scanned images.
(Receiving facilities, of course, can use electronic manifests/hybrid manifests, but as these manifests are signed electronically in EPA’s e-Manifest system and are submitted to the Agency instantaneously, the extra time to submit paper manifests is not applicable for these manifests. EPA charges the lowest user fee for electronic manifests.)
EPA believes that this additional time will allow receiving facilities to complete any steps necessary to modify their software systems and integrate them with e-Manifest so that they are in a better position to take advantage of the lower user fees for paper manifests submitted as “data plus image” uploads. Thus, this flexibility reduces costs to industry as well as reduces processing burden for EPA and sets up an important framework for entities to expedite their transition to fully electronic manifesting.
EPA encourages receiving facilities to submit paper manifests as soon as possible, rather than waiting until September 30, 2018. This will help both the receiving facility and EPA best manage, process, and bill for any manifests accumulated during this period.
Beginning on September 1, 2018, receiving facilities must submit all paper manifests to EPA within 30 days of receipt by the receiving facility, as required by the regulations.
- 2. What options will hazardous waste handlers have for submitting manifests once the e-Manifest system launches?
Receiving facilities will have several options for submitting their manifests to EPA. First, for electronic manifests, the receiving facility copy will be 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 three distinct options for submitting the final receiving facility copy to e-Manifest. First, the receiving facility may submit the top copy of the hand signed manifest to e-Manifest by mail for processing by the system’s paper processing center. Second, receiving facilities may instead upload a scanned image of the top copy of the manifest, again, to be processed by the system’s paper processing center. Finally, receiving facilities may utilize the third and preferred option for submitting the receiving facility paper copy, which involves uploading to the system both a data file and an attached image file copy of the form. This third option results in the lower paper processing fee, because the upload of the data file eliminates much of the manual processing that produces higher costs for the other paper submission methods.
EPA further notes that the first paper submission option – mailing the manifest form to the e-Manifest system – will be phased out on June 30, 2021, so that only the digital methods of paper copy submission will then be available to receiving facilities.
- 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 mail, scanned image, or data upload plus image. 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. Will the requirements in 40 CFR 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 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.
Manifest Preparation, Brokers
- 1. What methods of manifest preparation are supported in e-Manifest?
The e-Manifest system will support 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 will 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.
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 will retain 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 will 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 that will result under e-Manifest.
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. Will EPA or states be 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, will be effective in all states on June 30, 2018, which is also the date of the e-Manifest system launch. The Act provides that EPA will 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 has announced that e-Manifest will launch 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. Will 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 plan to 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 launches on June 30, 2018, the receiving facility copies of manifests may only be collected by e-Manifest, and not directly by the states. States will obtain their receiving facility data from the e-Manifest system rather than from the facilities. For electronic manifests, the EPA system will collect and retain 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?
States with connectivity to the e-Manifest system will 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?
EPA will coordinate to the extent feasible with states that have received misdirected manifest copies; however, ultimate responsibility lies with the receiving facilities, who are required by regulation to submit manifests to EPA. EPA expects that there will initially be communication challenges regarding the transition from state collection of manifests to EPA collection of manifests and we will work with our state partners to clarify the proper procedures.
- 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. Will the e-Manifest requirements become effective immediately on the same date in all states?
Yes, the e-Manifest requirements will become effective on the same date in all states. In its recent User Fee final rule, EPA announced that the effective date for the e-Manifest requirements and the e-Manifest system is June 30, 2018.
- 10. 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).
- 11. 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 will satisfy 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.Yes, the e-Manifest requirements will become effective on the same date in all states. In its recent User Fee final rule, EPA announced that the effective date for the e-Manifest requirements and the e-Manifest system is June 30, 2018.
- 1. Will there be a fee to use the e-Manifest system when it goes live?
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., direct mail, data file upload, image upload). EPA has not imposed fees on generators or on members of the pubic that would use the system only to access data.
- 2. How much will the e-Manifest system charge per manifest?
EPA will impose a per manifest fee for each manifest submitted to the system based on the type (paper or electronic) and mode of submission (mail, data upload, image file upload). EPA will publish the final fee schedule to the e-Manifest website prior to the system launch.
EPA published estimates of the initial fees in the preamble of the January 3, 2018, User Fee Rule. As of the issuance of the Fee Rule, our best estimates for the initial per manifest fees are:
- $4.00 for an electronic manifest (including hybrid)
- $7.00 for a data file upload of paper manifest data
- $13.00 for the upload of paper manifest image
- $20.00 for submission of a paper manifest form by mail
- 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. When will we post our user fees for e-Manifest?
EPA is required to accomplish full cost recovery with its user fees, so the final user fees will not be determined until EPA is able to fully assess the costs of operating the e-Manifest system. However, EPA published in the final User Fee Rule preamble a table showing estimates for the initial e-Manifest fees, based on the best and most current information on hand at the time of publication of the final rule. EPA will update the fee schedules on the e-Manifest web site, and final user fees should be in place in May 2018.
- 6. 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
Record Retention and Distribution
- 1. How long will 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 mail or 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 will support the entire manifest production, distribution, and record retention process for all the generators, transporter, and receiving facilities that participate in electronic manifesting and establish accounts in e-Manifest. The system will distribute and retain 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 will be distributed to the original generator, to the delivering transporter, and to interested states. Each of these electronic copies will be 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 will be 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 will collect and distribute only the final receiving facility copy, which the system’s operations staff will scan (if mailed to EPA) and then conduct data entry of the manifest data into the e-Manifest data system. For paper manifests that are not mailed to us, the system will receive a scanned image from the facility, and in many cases, a data file as well.
Since the e-Manifest system will only collect 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 will also have 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 will display 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. How long will EPA keep paper manifests that are mailed to EPA?
EPA will retain the original mailed copies only for the time required to create scanned images of these manifests and conduct data key entry activities to process the forms' data into the system. Once the paper manifests have been processed, EPA will recycle them.
Data Policy and Data Correction
- 1. How will the e-Manifest system allow for corrections? Who can correct a manifest?
EPA is implementing a manifest data corrections process that will enable any interested person to submit data corrections at any time after the receiving facility copy and data have been entered in the system. This data corrections process is projected to be available electronically to registered system users in the fall of 2018. When implemented, it will work 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 will retain 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. Will EPA prioritize processing of certain manifests over others?
No. Once EPA establishes that a submitted document is a valid manifest submission eligible for inclusion in e-Manifest, there will be no priority in the processing of manifests. Manifests including federal RCRA wastes will 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 manifests mailed to EPA.
- 4. When will the public have access to the e-Manifest data?
The public will generally have 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, data corrections, or 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 will be 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 will e-Manifest handle manifest discrepancy reports?
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, but we believe they will cause discrepancy reports to be less frequent. As waste handlers will 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 will also permit a generator to respond to such corrections. Thus, waste handlers would be 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 will retain 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 will be the source of the data for the data record in the system for that shipment. In most instances, that will be 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 will facilitate data quality in the manifest data system, particularly, as we move toward integrating the system with the biennial reporting process.
- 8. Will the e-Manifest system be linked to RCRAInfo?
Yes, e-Manifest will be linked to RCRAInfo and will have 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. Therefore, the use of e-Manifest will not yet replace the biennial report when the system launches on June 30, 2018.
- 1. 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 will need to request permissions for their specific site(s) once they gain access.
- 2. Is e-Manifest accessible on mobile devices, like a tablet or smart phone?
Yes, e-Manifest is accessible on mobile devices.
- 3. Can e-Manifest be used for both hazardous waste and non-hazardous waste shipments on the same truck?
- 4. Will the system generate automated notifications if manifests are pending for signature?
Yes, this functionality will be available, if not by the June 30th launch, then shortly thereafter.
- 5. Will the 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.
- 6. 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).
- 7. Will e-Manifest include state hazardous waste codes (in addition to federal hazardous waste codes)?
Yes. States have provided this information to EPA and it is available in the system.
- 8. Can you use an application interface (API) to sign manifests?
Not at this time. APIs will be available to push and pull data on manifest(s) but electronic signatures must be performed in the e-Manifest system.
- 9. 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. This functionality will be available; users can simply use the copy manifest icon on the e-Manifest dashboard.
- 10. 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.
- 11. 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”).
- 12. If a receiving facility is using a data upload to submit a manifest, how will the manifest numbers be 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.
- 14. How will 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.
- 15. Will there be “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.
- 16. How will e-Manifest handle password resets?
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.
- 18. If drivers do not carry mobile devices, how will 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.
- 19. 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.
- 20. 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.
- 21. Does e-Manifest allow use of decimals in the quantity field?
Not at this time. This is because the current paper manifest system does not allow for decimals. However, this is a potential change EPA could consider in the future.
- 22. Will those who use API services have to sign into the system to sign manifests?
Yes, for those companies that do not utilize their own CROMERR-compliant signature devices
- 24. 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.
- 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 participated in user testing for the e-Manifest module. Do I need to re-register for e-Manifest now that it has gone live?
Yes. User testing participants registered in the RCRAInfo pre-production database. The e-Manifest module has been launched 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 View manifests X X X X Create manifests or edit Draft manifests N/A X X X
Sign manifests or correct manifest data electronically, and submit manifests
N/A N/A X X Approve users and grant permissions (i.e. Viewer, Preparer, Certifier, and Site Manager) to other company contacts at a site. View billing invoices for a site as well as submit payments. N/A N/A N/A X
- 7. What is a Viewer?
As a Viewer, you can view manifest forms (i.e., the manifest, EPA Form 8700-22 and continuation sheet, 8700-22A) and data for specified sites within the e-Manifest module, but cannot create manifest forms, edit the information, or sign manifest forms.
- 8. What is a Preparer?
As a Preparer, you can perform the same functionality of a Viewer and also enter or edit data for specified sites within the e-Manifest module. You cannot sign and submit manifest information to EPA.
- 9. What is a Certifier?
As a Certifier, you can perform the same functionalities of a Viewer and Preparer, and can also electronically sign 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 and lower level 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. Will a Site Manager need an ESA for each site/EPA ID?
No. A user only needs to complete an ESA once. A Site Manager will not be 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, will I need to re-register for access to e-Manifest?
No, you will be able to access manifests and reports via the e-Manifest module in RCRAInfo. For state users that 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 states where users may begin registering as a Site Manager)?
The following states and territories have, as of May 22, 2018, 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)
Colorado (BR, myRCRAid)
Connecticut (BR, myRCRAid)
Hawaii (BR, myRCRAid)
Maine (BR, myRCRAid)
Montana (BR, myRCRAid)Navajo Nation (BR, myRCRAid)
Nebraska (myRCRAid)Nevada (myRCRAid)New Mexico (BR, myRCRAid)
New York (myRCRAid)
North Carolina (BR, myRCRAid)
North Dakota (myRCRAid)
Northern Marianas (BR, myRCRAid)
Oklahoma (BR, myRCRAid)
Puerto Rico (myRCRAid)
Rhode Island (BR, myRCRAid)
South Dakota (BR, myRCRAid)
Trust Territories (BR, myRCRAid)
Utah (BR, myRCRAid)
Vermont (BR, myRCRAid)
Virgin Islands (BR, myRCRAid)
West Virginia (BR, myRCRAid)
- 20. Why do state users of e-Manifest also need an account in RCRAInfo Version 5 production?
State users will need version 5 of the RCRAInfo production system to take advantage of the reporting features of the Basic RCRAInfo Reporting Tool (BARRT) for e-Manifest. EPA has built an e-Manifest interface in BARRT so state inspectors can perform manifest reviews prior to conducting an on-site inspection by using the pre-built SQL queries in BARRT or create their own query to pull manifest data from the e-Manifest module.
- 22. How will my company’s information be 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 will be 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.
- 23. Do receiving facilities that mail in paper copy manifests to EPA have to register for e-Manifest?
Yes. All receiving facilities must register for e-Manifest, even if they choose to mail their paper manifests to EPA. Since EPA will create images of paper manifests and key in the data, these receiving facilities must register to view the copies of record that the system will retain in the facilities' accounts, as well as to submit subsequent data corrections related to these manifests. EPA also notes that it will not accept paper manifests submitted through the mail after three years and thus these facilities should plan to transition to submitting paper manifests via scanned images or data uploads (or, better yet, transition to electronic manifests).