- NEW! Effective October 1, 2019, the EPA e-Manifest user fees are changing. Read more below ...
To support e-Manifest operations, the EPA imposes a user fee for every manifest, whether paper or electronic.
This manifest fee is assessed to the receiving TSDF by EPA and is subject to change.
In a statement released by The EPA announcing the fee changes: "For FY2020/2021, the user fees are changing due to various factors, including changes in projected manifest usage rates as well as program costs during this period. These new user fees will be in effect from October 1, 2019, through September 30, 2021."
Please visit the EPA website for more information regarding EPA e-Manifest User Fee Schedules
As a result, Tradebe will also increase our manifest fee structure that will cover the EPA increase as well as other costs Tradebe incurrs in order to comply with EPA's e-Manifest program requirements. These costs include developing, operating, maintaining and upgrades to infrastructure necessary to support the e-Manifest system.
The Hazardous Waste Electronic Manifest, colloquially called e-Manifest, is a national database for electronic cradle-to-grave tracking of all hazardous waste shipments intended to replace the current paper-based system.
The centralized and digital platform, operated by the United States Environmental Protection Agency (EPA), records and tracks all hazardous waste manifest activities in the United States.
Data from all RCRA hazardous waste shipments must be transferred to EPA’s e-Manifest National Database system. The database launched on June 30, 2018.
Since the launch of e-Manifest over a year ago now, Tradebe's team has been working hard to implement the necessary technology and process changes to support the new e-Manifest requirements. Tradebe is focused on managing the costs of the new program so as to minimize its continued impact on our clients.
- Designed to modernize the EPA national tracking of hazardous waste shipments into a single hub while improving accuracy, processing and correction of hazardous waste manifests;
- Increase the effectiveness of compliance monitoring for Regulators while providing potential for RCRA biennial reporting integration and other federal/state systems;
- Not a mandatory program, although the incentives (fees) are established by the EPA with the intent to “end” paper copy shipments in three to five years;
- States that require Very Small Quantity Generators (VSQGs) to use a Hazardous Waste Manifest can also elect to ship on electronic manifest;
- Manifest information will be available to the public 90-Days after receipt at the Receiving Facility;
- To participate and view e-Manifest data, all Handlers (e.g., Generator, Transporter and Brokers) must register in the e-Manifest program.
- All corrections to the e-manifest and paper manifest data must be done electronically. A Handler making the correction must certify and send an electronic notification to all Handlers identified on the manifest
To minimize customer disruptions, Tradebe will implement changes in phases.
Currently during Phase I:
- Tradebe will continue to accept paper manifests for all shipments and submit the manifest in a data file upload to USEPA’s National Database;
- Tradebe began to submit manifest information to the EPA electronically on June 30, 2018 for manifests dated by the Generator on or after June 30, 2018; and
- Tradebe, as a transporter, initially will not equip drivers with electronic signing devices until after the required CROMERR signatures process is fully established by the EPA.
If your company is planning on creating manifests electronically, or as a hybrid where the transporter creates the electronic manifest,
please contact us ASAP at email@example.com to coordinate with Tradebe facilities in order to avoid unnecessary delays.
Also, loads must be scheduled as is usual - the use of e-Manifest does not eliminate this necessary step.
The EPA's New 5-part hazardous waste manifest forms are now available for ordering through the vendor of your choosing.
The New 5-part manifest form cannot be used until June 30, 2018.
The Current 6-part manifest form can be used until the Handlers (generator/transporter/Receiving Facility) inventory runs out.
For those clients who will continue to have Tradebe prepare their manifests - no action is required. However, if you prepare your own or wish to do so going forward, the following links to JJ Keller are provided as a resource:
THE EPA HAS MODIFIED THE CURRENT REGULATIONS REGARDING THE TRANSPORTER'S ABILITY TO CHANGE TRANSPORTER(S) FOR SHIPMENTS IN-TRANSIT.
While designed to improve communication and awareness of Transporter activity, this modification to the regulations also provides the option to have a specific agreement between the generator and the initial transporter of waste to facilitate changes.
To comply and streamline your shipments with this new requirement, Tradebe is requesting customers' acceptance to provide Tradebe Transportation and all of its subsidiaries with explicit authority to continue to modify, add/or substitute transporters for the purpose of transportation efficiency, convenience, safety or response to an emergency.
REVIEW AND ACCEPT TRADEBE'S TRANSPORTATION AUTHORIZATION CONTRACT NOW
Save the completed form that you receive via email as your copy of the agreement.
MORE DETAILS REGARDING EPA'S NEW TRANSPORTATION/AUTHORIZATION REQUIREMENT:
EPA is classifying the initial transporter’s authority that would allow them to change the transporter(s) designated on a manifest, or to add a new transporter to the manifest. A transporter may make these changes during the course of transportation of wastes; as a result to respond to an emergency, or for the purpose of transportation efficiency, convenience, or safety. The modification to the regulations mandates a specific agreement between the generator and the initial transporter of the waste making the changes.
EPA’s Transporter classifications are a:
- Transporter without agency authority; or
- Transporter with agency authority.
A Transporter without agency authority:
Is a transporter without contractual authorization in place from the generator, whereas to act as an agent on behalf of the generator. Therefore the transporter must contact the generator for permission prior to making any revisions or additions to the transporter section on the manifest.
A Transporter with agency authority:
Is a transporter with contractual authorization in place from the generator, to act as the generator’s agent.
For these transporters, EPA modified the regulations so that transporters (or brokers), who intend to oversee and control the routing of the shipments on behalf of the generator, must enter the following statement in Item 14 of the manifest:
‘‘Contract retained by generator confers agency authority on the initial transporter to add or substitute additional transporters on generator’s behalf.’’
It should be noted, states could pursue enforcement actions against generators for failure to produce the contract upon request as well as pursue enforcement actions against the transporters for failure to comply with adding the statement language in Item 14 of the manifest.
Archive Links to EPA Webinars:
- “How to Register to Become an e-Manifest System User”
- “What Generators Need to Know”
- “What Transporters Need to Know”
- “What Receiving Facilities Need to Know”
Please visit the EPA site for more information on the most current webinars at https://www.epa.gov/e-manifest/monthly-webinars-about-hazardous-waste-electronic-manifest-e-manifest
The EPA has released a series of e-Manifest Fact Sheets.
- e-Manifest Brokers Fact Sheet (PDF)(2 pp, 276 K)
- e-Manifest General Public Fact Sheet (PDF)(2 pp, 231 K)
- e-Manifest Generators Fact Sheet (PDF)(2 pp, 202 K)
- e-Manifest Receiving Facilities Fact Sheet (PDF)(2 pp, 204 K)
- e-Manifest Site Managers Fact Sheet (PDF)(2 pp, 204 K)
- e-Manifest State Program Fact Sheet (PDF)(2 pp, 269 K)
- e-Manifest Transporters Fact Sheet (PDF)(2 pp, 207 K)
- e-Manifest TSDF Fact Sheet (PDF)(2 pp, 228 K)
EPA e-Manifest General Resources:
- EPA e-Manifest site: https://www.epa.gov/e-manifest
- EPA e-Manifest Fact Sheets: www.epa.gov/e-manifest/fact-sheets-e-manifest-stakeholder
- EPA e-Manifest Registration Information: https://www.epa.gov/e-manifest/e-manifest-user-registration#who_register
- EPA RCRAInfo Registration: https://rcrainfo.epa.gov/rcrainfoprod/action/secured/login
- EPA Frequently Asked Questions & Learning Zen: https://rcrainfoindustry.learningzen.com/PremiumServices/login/PortalRegistration.aspx
EPA e-Manifest Helpdesk:
- Industry Users: 8:00 am - 6:00 pm EST at (833) 501-6826 or (970) 494-5508; or Email at firstname.lastname@example.org
- State Users: Contact EPA Regional contacts; or email at eManifest@epa.gov
Tradebe e-Manifest Email Campaign Archive:
- 08/22/2019 - Tradebe e-Manifest EPA User Fee Increase Notification - coming soon!
- 07/11/2018 - Tradebe e-Manifest Transporter Agreement Notification
- 06/30/2018 - Tradebe e-Manifest Launches Today!
- 06/14/2018 - Tradebe e-Manifest Fee Notification
- 06/12/2018 - Tradebe e-Manifest UPDATE
- 06/07/2018 - Tradebe e-Manifest UPDATE
- 05/14/2018 - Tradebe e-Manifest UPDATE
- 04/05/2018 - Tradebe e-Manifest Notification
Tradebe's e-Manifest Team is here to assist; email us at: email@example.com.
Subscribe to receive Tradebe news and updates on e-Manifest and more!