WHAT’S GOING ON ?
The 40 CFR Environmental Protection Agency (EPA) Hazardous Waste e-Manifest website regulations are not a road or a path you follow, they are more like a quilt. Small pieces and patches of requirements from different sections of regulations that must be stitched together.
Sew, with the help of Luke (a longtime client), Jeff (a contemporary), Bryan (EPA), Linda (a longtime client), then Luke along with Jennifer at the Pennsylvania Department of Natural Resources (PADNR), and the material in the Federal Register Reprint Service, here’s what Lisa helped me put together.
Visit Frequently ask questions about e-manifest.
Register, as all large and small quantity generators must be registered with RCRAInfo. This will enable generators to access and maintain final hazardous waste Treatment Storage Disposal Facility, (TSDF) manifest acceptance copies online.
Visit: Reporting and Fee Collection Division and RCRAInfo for registration instructions.
Continue using the current five form paper or online manifests and mailed reports until December 1, 2025, even after the new e-manifest system, with its four form manifests and its new online Exceptions, Discrepancies, Unmanifested Waste and Export Reports is up and running.
Start using, upon approval, either the new four form paper or online hazardous waste manifest, and the online filing of the Exceptions, Discrepancies, Unmanifested Waste and Export Reports into the e-manifest system. You can also continue using the current five form paper or online hazardous waste manifest, until December 1, 2025 at your discretion.
Open The EPA E- Manifest Website
Stop, using the current five form hazardous waste paper form and online manifests on December 1, 2025, then begin submission of the paper or online four form hazardous waste manifest. In addition the paper Exceptions, Discrepancies, Unmanifested Waste and Export Reports will no longer be accepted by mail.
FREE DOT EPA OSHA Federal Register Reprint Service
Print, or provide a paper copy of the EPA hazardous waste manifest, to the transporter’s driver, for use as the 49 CFR Department of Transportation, (DOT) hazardous material shipping paper regardless of which manifest is used.
Luke, after IATA Dangerous Goods training, was the first to ask me “What’s going on with the manifest?” I said, "I don't know, What’s going on with the manifest ?” So Lisa, upon being informed of my ignorance, immediately gathered the new e-manifesting requirements from her federal register updates and sent them off to Luke.
Bryan at EPA, was next (helpful, friendly and forthcoming), he was listed as the contact in the Federal Register. He helped me to better understand evolving procedures and the timelines for the new four form e-manifest’s approval. Linda, a close and nearby client, furnished us with a few more pieces or patches with her e-manifest experiences and anticipated e-manifest system concerns.
Luke and Jennifer at PDNR from start to finish furnished their insights and offered to answer written questions if needed.
It seams, sometime before December 1, 2025, EPA will be removing Form 3 or the “Designated Facility Copy” from the waste manifest and begin accepting online Exceptions, Discrepancies, Unmanifested Waste and Export Reports as the reports will no longer be accepted by mail after that date.
However, generators may continue to use the online and paper O.G. 5 form manifest, until December 01, 2025 or the online or paper four form manifest once approved.
My wife Erin is an accomplished quilter. Me, I’m more of a blanket guy, as in “Pigs in a Blanket”. If you have any questions, concerns or comments, please reach out,
Robert J. Keegan
Publisher and President
Hazardous Materials Publishing Company
Transportation Skills Programs
hazmat.tsp@gmail.com
Text me at 610-587-3978