On July 26, 2024, the Environmental Protection Agency (EPA) published its final rule Integrating e-Manifest with Hazardous Waste Exports and Other Manifest-Related Reports, PCB Manifest Amendments, and Technical Corrections. The Third Rule, as it’s referred to by the EPA, takes effect on January 22, 2025. The changes are expected to increase the usefulness of the e-Manifest system and improve tracking of hazardous waste shipments.
The final rule amends certain aspects of the hazardous waste manifest regulations under the Resource Conservation and Recovery Act (RCRA), specifically related to the Hazardous Waste Electronic Manifest (e-Manifest) System. e-Manifest was implemented in 2018 to electronically track hazardous waste shipments in the United States.
One of the more significant updates for companies using a waste vendor that ships waste outside of the US, is that the final rule requires that manifests from exported hazardous waste shipments be submitted by the exporter to the e-Manifest system and the user fee be paid. EPA expects approximately 22,000 additional export manifests will be available annually in the system when the final rule takes effect.
Prior to this, for waste shipments sent outside of the US such as to Canada, waste vendors had to mail the final manifest to the company that had generated the waste. It was then the responsibility of the waste generator to upload a copy of the manifest to their e-Manifest account or mail a paper copy to the Massachusetts Department of Environmental Protection (MassDEP), New York State Department of Environmental Conservation (DEC), or other appropriate state agency depending on location.
The Third Rule also includes these additional changes:
- Expanding the required data on the manifest forms corresponding to their completion for international shipments.
- Revising the export and import “movement document” requirements to more closely link the manifest data with the movement document data for manifest tracking purposes. These changes will assist with integration of EPA’s Waste Import Export Tracking System (WIETS) into RCRAInfo.
- Integrating three manifest reports (i.e., Exception Reports, Discrepancy Reports, and Unmanifested Waste Reports) into e-Manifest.
- Requiring small and large quantity generators to register for access to e-Manifest to obtain their final signed manifest copies from the system.
- Aligning the polychlorinated biphenyls (PCB) manifest requirements under the Toxic Substances Control Act (TSCA) with the RCRA manifest regulations and the e-Manifest system.
- Incorporating miscellaneous corrections such as removing obsolete requirements, fixing typographical errors, and adding new definitions.
For more information on the changes published in EPA’s Third Rule, or for help implementing them at your facility, please contact us.
This blog was written by Beth Graham, Safety Partners’ Director of Quality, Research, and Training
