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An electronic manifest is the electronic format of the uniform hazardous waste manifest obtained and completed through the e-Manifest system. (Manifests obtained through registered printers are referred to as paper-based manifests.)

The manifest is used to track hazardous waste from the time it leaves the generator facility where the waste was generated until it reaches the designated receiving facility that will treat, store, or dispose of the hazardous waste.

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Yes, the e-Manifest system stores final copies of all manifests, both electronic and paper. Receiving facilities that receive waste that must be manifested under federal or state law must submit those manifests to EPA using one of the available submission options. Once submitted, states and industry can make corrections to their paper manifest data electronically in e-Manifest through the post-receipts corrections process; the system retains an auditable record of all such corrections.

Yes, there are a couple ways that field personnel, employees and contractors with direct physical responsibility for the waste shipment, can sign electronic manifests through a Remote Signer, a registered user in RCRAInfo with sufficient access to sign electronic manifest. The field personnel does not need to be registered in either scenario:

The 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.

The hybrid or mixed paper/electronic manifest is a specific manifest approach that EPA adopted to assist generators who are not able to fully participate in electronic manifesting at the time of system launch. The hybrid manifest allows transporters to initiate an electronic manifest in e-Manifest and use this manifest with their non-participating generator customers. The initial transporter may print a copy of the electronic manifest for the generator, and the generator may sign the paper copy, obtain the initial transporter's ink signature on this paper copy, and then retain this paper copy on-site as the generator's initial manifest copy as is done under traditional manifest requirements. Thereafter, the initial transporter and subsequent waste handlers complete the remainder of the tracking of the shipment electronically in e-Manifest with electronic signatures and electronic transmissions to the system. Hybrid manifests are charged the same fee as a fully electronic manifest. Generators that utilize hybrid manifest are also given paper copies of completed manifests from receiving facilities.

Yes, the e-Manifest system collects manifests for wastes shipped on a manifest, where the manifest is required either by federal law, or the law of the generator state or destination state. Users who use the manifest voluntarily for their waste shipments (i.e., the manifest is not required by federal or state law) are not required to submit their manifests to the e-Manifest system.

If either the generation state or receiving state requires a manifest during the movement of the waste shipment, then the receiving facility must submit the manifest to the system and pay any applicable fees associated with that manifest. If the generation state requires a manifest, the receiving facility must submit this manifest to e-Manifest, even in instances where the waste is not regulated in the destination state and does not legally require a manifest under the laws of that state. This enables the origination state to confirm the proper receipt of its regulated wastes, even when those wastes are shipped out-of-state for management.

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.

In the Generator Improvements Rule, EPA promulgated a regulation to allow VSQGs to ship their hazardous waste off-site to an LQG for consolidation if the VSQG and the LQG are under the control of the same person, and the VSQG complies with specific conditions for marking its containers. Under the federal rules, if a VSQG meets the conditions for shipment to LQGs under control of the same person, the shipments to the LQG are not required to use a RCRA manifest to track these shipments. Shipments of waste not subject to the manifest under either federal or state law are not subject to e-Manifest requirements.

Note that states authorized for the RCRA program must adopt the provision allowing consolidation of VSQG waste at an LQG before entities within that state can start operating under the provision. In addition states can be more stringent in their regulations. For site-specific questions, please contact your authorized state.

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.

Yes. Unless specifically exempted from the requirements in 40 CFR part 761 subpart K. The PCB regulations require generators to prepare a manifest on EPA Form 8700-22, and, if necessary, a continuation sheet prior to transporting regulated PCB waste. Regulated PCB waste(s) means those PCBs and PCB Items that are subject to the disposal requirements of 40 CFR part 761 subpart D. Refer to 40 CFR section 761.207 for more information.

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.

This answer depends on the state and if the waste contains PCBs subject to the manifesting regulations and policies per title 40 CFR part 761. In general, VSQG/CESQG waste are exempt federally from the RCRA manifest, provided the regulatory conditions for the exemptions are met. Where these exemptions are applicable (i.e., in unauthorized states and in authorized states that have adopted these manifest exemptions), these wastes are exempt from manifest requirements and therefore are not subject to e-Manifest.

However, in some authorized states, the states have elected to require manifests for VSQG/CESQG waste shipments. In such cases, the manifests required by the states to track these shipments are subject to e-Manifest.

With regards to PCB shipments, unless specifically exempted from the requirements in 40 CFR part 761 subpart K, the PCB regulations require generators to prepare a manifest on EPA Form 8700-22, and, if necessary, a continuation sheet prior to transporting regulated PCB waste. Regulated PCB waste(s) means those PCBs and PCB Items that are subject to the disposal requirements of 40 CFR part 761 subpart D. Refer to 40 CFR section 761.207 for more information.

Additionally, the federal rules addressing VSQGs require manifests for certain episodic waste events at VSQGs. When such an episodic event occurs, and the VSQG rules apply, then these shipments and their manifests would be subject to e-Manifest.

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.

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.

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.

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.

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.

Yes. Generators that are registered and maintain access to e-Manifest can use the records stored in e-Manifest to satisfy the manifest recordkeeping requirements. These generators can also print hard copies of their manifests from the system at the request of a federal or state inspector. Federal or state inspectors can also use e-Manifest to perform manifest reviews prior to conducting an on-site inspection, and obtain copies of the manifests prior, and subsequent, to the inspection. 006ab0faaa