The Road to Electronic Manifest Tracking


In 2006, a system was proposed where the EPA was exploring the possibility of implementing and hosting an IT platform to manage and track shipment of hazardous waste across the country.  The overall response was positive with the exception of a some concerns (ie. confidential business information, web security, difference in state hazardous waste disposal regulations, and state and federal reporting requirements).  Since the initial request for commentary was issued in 2008 the proposal seemed to stop dead in it's tracks.  The only information provided by the EPA was that, due to the concerns that were very valid, the EPA would need to do more research in the tangibility of the potential system implementation at a federal level.

On August 2, 2012 the Senate passed "S. 710: Hazardous Waste Electronic Manifest Establishment Act."  This bill amends the Solid Waste Disposal act to direct the administrator of the EPA to establish a hazardous waste e-manifest system and implement the system in all states.  This bill lends support to the e-manifest tracking system initially proposed in 2006 and could very well resurrect the forward movement of that program.

How this effects us:

  • Generators would be required to use the web based e-manifest system to sign and certify e-manifests generated for transport to treatment facilities.  Special exceptions would be made based on state shipping requirements for CESQG's.
  • Transporters would either need to carry a hard copy of the e-manifest or an electronic device to reference the generator certified e-manifest for DOT to meet regulations. (Another option that was discussed since 2006 was the real-time information posted to the system that could be made available to DOT & EPA for live tracking of hazardous waste shipments across the country).
  • Treatment Facilities (TSDF) would need to implement the use of the e-manifest system to accept hazardous waste transported to their facility.

For more information on the 2006 proposal click here.
For more information on the Hazardous Waste Electronic Manifest Establish Act click here.

Posted By: Douglas Kongaika
Location: Rockville, MD, USA

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