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The Manifest: Under the 6 page manifest system currently in effect, the hauler brings the manifest duly completed to the generator. The Generator must verify all information on the manifest as any inaccuracy on the manifest brings liability to the generator. We note that the federal manifest and CA manifest are the same but California has more wastes that have to be manifested. California also has more taxes on the hazardous wastes generated including some complicated reporting requirements for large generators (over 12 tons/year). The good news is that only some of the waste dealers produce needs a manifest.
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The Manifest Process (Now): The person designated by the generator signs the manifest acknowledging the nature and amount of waste being hauled away. The driver for the waste hauler leaves a copy (Copy 1) with the generator. The Generator then mails a photocopy of Copy 1 to Cal/EPA in Sacramento (Generator Manifests, PO Box 400, Sacramento CA, 95812). Within 45 days, the generator will receive a second copy (Copy 2) of the manifest from the TSDF with signature at the bottom acknowledging reciept of the waste. Copy 2 must be matched with Copy 1 and maintained in files for a period of 3 years. In the event Copy 2 is not received, the hauler/TSDF must be contacted. Copy 3 is mailed to the EPA by TSDF, Copy 4 is kept by the TSDF and Copy 5 is kept by the hauler. Copy 6 is for the 2nd hauler, if any.
Federal manifest procedures are listed here.
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Paperless Process: The EPA established the e-Manifest system according to the Hazardous Waste Electronic Manifest Establishment Act, enacted into law on October 5, 2012. The “e-Manifest Act” authorizes the EPA to implement a national electronic manifest system and requires that the costs of developing and operating the new e-Manifest system be recovered from user fees charged to those who use hazardous waste manifests to track off- site shipments of their wastes. In January 2018, the EPA published its final methodology for setting user fees based on the costs of processing manifests. By enabling the transition from a paper-intensive process to an electronic system, the EPA estimates e-Manifest will ultimately reduce the burden associated with preparing shipping manifests by between 300,000 and 700,000 hours, saving state and industry users $75-$90M annually.
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June 30, 2018: Now 6 years later, the e-Manifest Act is taking effect, which makes two changes to the current manifest system. The first change is that waste generators will be allowed to submit hazardous waste manifests electronically through the EPA’s e-Manifest system. Generators looking to use the e-Manifest system must register online here. The registration process requires confidential information and must be completed by at least two dealership managers. We have provided a step-by-step guide for e-Manifest registration here. The second change happening to the manifest system is that the EPA will charge the TSDF a fee for every manifest produced. TSDF’s are expected to share this expense with generators.
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The EPA’s goal is to phase out the paper manifest system and replace it with the e-Manifest within the next 5 years. Since this law is in its early rollout phase there are going to be updates and changes as the EPA, generators, waste haulers, and TSDF’s adapt to the new system. Below we have outlined the different ways dealerships can currently submit manifests:
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OPTIONS AVAILABLE NOW:
1. Mailed Paper Manifest: The generator, waste hauler and receiving facility all sign on paper. If the dealership is NOT registered for e-Manifest, follow the old paper manifest procedures outlined under The Manifest Process on the previous page. Generators using this option do not need to register on the EPA website. Fee is $20/manifest.
2. Registered for the E-manifest: As explained on the previous page, if the facility is registered for the e-manifest system, then the paper copy of the manifest can be submitted electronically as a PDF scan or image upload. Fees are less than that for option 1 above.
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OPTION IN THE FUTURE (THE MODERN AGE):
Paperless Option: The dealership must be registered on the e-Manifest website. The generator, waste hauler and TSDF will all sign electronically. The hauler(s) have to develop software that can communicate with the state and federal agencies. We are told this can take up to 5 years. Haulers are expected to keep generators informed as the paperless system becomes available.
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References: https://www.epa.gov/e-manifest & https://www.epa.gov/sites
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Celly Services Inc. 