With EPA’s e-Manifest set to officially launch on June 30, 2018, companies need to begin preparing to register for the system. Here is the latest information from EPA about how the registration will work.
All receiving facilities must have an EPA ID number by June 30, 2018, regardless of whether they will be using paper or e-Manifests. The receiving facilities are the parties that will be responsible for payment of the user fees and the EPA ID number will be the means for tracking billing. Generators will also need an EPA ID number if they want to sign electronic manifests or correct manifests post-receipt. Transporters that do not already have an EPA ID number will need one if they want to sign electronic manifests.
Facilities can obtain an EPA ID number from their states, except that facilities in Iowa, Alaska and New York will need to request one from their EPA Regional office. Facilities will need to complete EPA’s Site Identification Form 8700-12 to obtain the EPA ID number. In states that have opted in to the EPA MyRCRAid electronic submittal program, the form can be submitted electronically. Facilities will need to complete Items 1-10, 18 and 19 on the form. Under the reason for submittal on the form, the party should mark “on-going regulated activity.” If a facility already has an EPA ID, they do not need to do anything further.
The e-Manifest system will be linked to EPA’s RCRAInfo program. Currently, RCRAInfo is used for electronic submittals of the Site ID Form (8700-12) and Biennial Report (8700-13), for states that have opted in to the electronic reporting. Once e-Manifest launches, RCRAInfo will also be used for the electronic submittal of the Uniform Hazardous Waste Manifest (8700-22) in all states. The basic instructions for completing the e-manifest will not be materially different from submitting a paper manifest. The data elements will remain the same, but the instructions will be updated to address completing the electronic form and signing the form electronically.
Companies can start registering site managers now under the RCRAInfo system for those states that have opted in to the Biennial Report and/or My RCRAid under the RCRAInfo system. The site manager will have permission to view, prepare and sign forms for their sites, in addition to approving other users in their company. EPA is recommending that each site register at least two (2) site managers, but they can register more and site managers can be registered for multiple sites. If a company registers now, they will automatically gain access to the e-Manifest system when it launches. EPA will announce when registration will be open in all states.
The takeaway is:
- If you don’t have an EPA ID and will be receiving waste, you need to request an EPA ID from either your state or EPA regional office; and
- Register now at least two (2) site managers for your company for those states that have opted into the Biennial Report and /or My RCRAid programs.
We will continue to keep you posted on developments as they become available.