There are many moving parts involved with the launch of the e-Manifest system, which occurred over the summer. Under the new regulations, receiving facilities must submit paper manifests to EPA within 30 days of receipt. Although EPA is encouraging facilities to submit the paper manifests as soon as possible, they have granted an extension for manifests received between June 30, 2018 and September 1, 2018. Paper manifests received during this time period must be submitted to EPA by September 30, 2018.
The extension was issued with hopes that receiving facilities would be able to use this time to submit their manifests as data files plus scanned images of the manifests rather than mailing the original paper manifest. This is the lowest cost option of the three options for manifests initiated on paper. These ‘data plus image’ uploads are the cheapest, with the next tier being scanned manifest images, and the highest cost option being paper manifests mailed to the EPA. Of course, fully electronic and hybrid manifests are also electronic options.
Remember it is the responsibility of the receiving facility to submit manifests to the EPA under the new regulations. Be sure to check with your state agency to determine if they still require generators to submit copies of their manifests.