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e-Manifest User Fee Proposed Rule Signed

On June 27th, 2016, the EPA Administrator signed the e-Manifest User Fee Proposed Rule. The Hazardous Waste Electronic Manifest Establishment Act requires the EPA to create an electronic system to track hazardous waste shipments, so the implementation of a national e-manifest system is expected in the spring of 2018. Users of the system will be charged fees in order to recover the costs associated with the development and operation of the e-manifest system.

The implementation of e-manifests will be a major change for generators of hazardous waste, and should serve as a reminder that generators are responsible for waste ‘cradle to grave’. When waste leaves your site, you company is still responsible for that waste and any issues that may arise during the transportation, treatment, and disposal of the waste. It is critical that all waste is properly collected, classified, and labeled so it is handled appropriately. This starts with the generator of the waste knowing the constituents being placed into the initial container established for waste collection. The generator is responsible for properly labeling the waste with those constituents. The label is used to help develop a waste stream information profile (WIP) for the waste, which is then used to develop a manifest for the waste when it is removed for off-site treatment and disposal. The TSDF that receives the waste then uses that manifest to determine how to treat the waste. Generators should be reminded of the importance of properly labeling waste on a regular basis.

If you have not done a full review of your hazardous waste program in a while, take the time to talk to the generators of waste at your site to ensure the waste program changes as the lab procedures change.

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