Latest Developments: U.S. EPA's Advisory on Ensuring RCRA Compliance via E-Manifest Data Accuracy

The electronic manifest (e-Manifest) is a relatively new introduction by the EPA in line with today’s rapid adoption of technology for automating standardized forms. While this e-Manifest system has been active since June 30, 2018, its use has only been fully taken advantage of in the past few years.

What is an e-Manifest?

An e-Manifest, or electronic manifest, is an electronic system used by the United States Environmental Protection Agency (EPA) to track the movement of hazardous waste from the generator to the final disposal or recycling facility. The e-Manifest system aims to improve the accuracy, efficiency, and transparency of hazardous waste management by replacing the traditional paper-based manifest system with an electronic one.

Although the e-Manifest system has simplified the process of filling out mandatory forms, hazardous waste generators utilizing this system need to recognize the significance of incorporating all data to ensure safety during handling and transporting such hazardous waste and for the accuracy of records maintained. 

Regulators recently emphasized the significance of maintaining complete and accurate manifests to track shipments in the e-Manifest system. In fact, a Compliance Advisory was recently issued by the U.S. Environmental Protection Agency (EPA) to hazardous waste generators and receiving facilities detailing the primary concerns regarding the incomplete hazardous waste manifest date. 

The three most common issues of data incompleteness and accuracy submitted in the e-Manifest system are detailed below:

Inaccurate or Missing EPA ID Number

Many waste generators who use the e-Manifest system tend to miss out on filling in their EPA numbers. Cases most commonly include small quantity generators (SQG), and very small quantity generator (VSQG) sites. They fail to provide an EPA ID number, which is required in certain situations such as when a state requires a manifest for "non-RCRA" waste or when a VSQG uses the exemption for episodic events.

Mis-matching or Invalid Manifest Tracking Numbers (MTN)

Another common problem that arises is the use of invalid tracking numbers or electronic submissions in the-Manifest system. It is normal practice that each manifest is printed with a unique tracking number by the limited approved and registered vendors. Generators are required to use only these approved manifests. However, the EPA receives manifests with invalid tracking numbers or electronic submissions that use MTNs that do not match the hard copy of the manifest.

Electronic Submission and Typo Errors

A very common error made during online submissions is typographic errors. Hazardous waste generators using the e-Manifest systems must ensure that the data entered through the electronic system is accurate and complete and devoid of any typos. 

The EPA also faces issues with paper-based manifests where the writing on a paper manifest is illegible!

The Compliance Advisory warns that hazardous waste generator facilities that submit incomplete or inaccurate data through the e-Manifest system may face enforcement action by the EPA. It is important for hazardous waste generators and receiving facilities to ensure that their e-Manifest data is accurate and complete to comply with RCRA requirements.