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National e-Manifest System

*For general information about completing hazardous waste manifest forms, special assessment taxes and fees, or the adoption status and background information related to the e-Manifest rules, please see the "Important Links" section in the column on the right side of this page*

Background

The United States Environmental Protection Agency (EPA) is currently developing a national electronic manifest (e-Manifest) system (link leaves DEC's website) that will facilitate the tracking and transmission of the EPA uniform hazardous waste manifest form (EPA Form 8700-22) using a web browser. This system will be implemented by the EPA in partnership with industry and states. The new system will be designed to make manifesting more effective and convenient for users. Paper manifesting will still be allowed under this new system, however, the cost of using paper manifests will be higher than using electronic manifests. For paper manifests, a newly revised version of the paper manifest form will be required (a new 5-copy manifest will be used instead of the old 6-copy manifest). The e-Manifest system launched on June 30th, 2018.

Manifests that must be submitted to e-Manifest: Hazardous waste manifests need to be submitted if they are used to ship a waste that is required to be transported using a hazardous waste manifest by EPA or the state regulations of the generator state or destination state.

Submitting Paper Manifests to e-Manifest

Receiving facilities should mail final paper hazardous waste manifests and associated continuation sheets to EPA's paper processing center at the following address:

EPA e-Manifest PPC
14295 Park Meadow Dr. - 5th Floor
Chantilly, VA 20151

The Regulated Community and e-Manifest

On July 17, 2018, DEC issued an enforcement discretion letter implementing certain provisions of EPA's e-Manifest rule in New York State. The letter describes how DEC will exercise enforcement discretion with respect to certain less-stringent provisions of EPA's e-Manifest rule. The letter also discusses the more stringent New York State requirements that will be maintained. The letter can be accessed here: DEC e-Manifest Enforcement Discretion Letter (PDF, 76 KB, 2 pages).

The regulated community can prepare themselves for the new e-Manifest system by taking advantage of the various outreach materials provided by EPA.

EPA conducts webinars (link leaves DEC's website) related to the development and progress of the e-Manifest system initiative; archived copies of previous e-Manifest webinars are located on the same webpage. EPA's e-Manifest team provides updates through the EPA e-Manifest listserv and EPA Monthly Update webpage. These updates cover a range of topics including system development, implementation, and various meetings and workshops. You can access these updates by subscribing to EPA's e-Manifest listserv (send a blank e-mail to eManifest-subscribe@lists.epa.gov to subscribe) or visiting EPA's e-Manifest Monthly Update webpage (links leave DEC's website).

Verify Your Site Information (Recommended)

It is recommended that you use RCRAInfo Web (link leaves DEC's website) to verify that the EPA ID number, site name, location address, mailing address, and contact phone number that are associated with your site are correct. The information associated with your site in RCRAInfo will be used on your electronic manifests in the e-Manifest system, so it is important that the information in RCRAInfo is correct. Site information can be updated in the myRCRAid module of the RCRAInfo Industry Application (App) (link leaves DEC's website).

Site Identification (ID) Numbers

EPA Region 2 issues the EPA ID numbers for sites located in New York State. EPA ID numbers are assigned to a site's physical location (an EPA ID number does not transfer with the handler if the handler moves to a different site). Small quantity generators (SQGs), large quantity generators (LQGs), and treatment, storage, and disposal facilities (TSDFs) are required to have an EPA ID number. EPA ID numbers for New York facilities beginning with "NYP" are provisional ID numbers and should only be used for 30 days after the number is issued. EPA ID numbers for New York facilities beginning with "NYP" or "NYN" should not be used as the permanent EPA ID number for a site in the e-Manifest system, please contact EPA Region 2 for details. For more information about New York site locations, please see the EPA Region 2 webpage on obtaining EPA ID numbers (link leaves DEC's website) or call EPA Region 2 at (212) 637-4106.

Communicating with Transporters and Receiving Facilities

Generators will need to communicate with their selected transporters and receiving facilities (e.g., TSDF, recycler, etc.) to decide who will be responsible for creating new manifests and whether paper or electronic manifests will be used; this will help to prevent duplicate manifests for the same shipment.

Receiving facilities will be responsible for the submittal of final, signed manifests to the e-Manifest system and the payment of associated fees. It is recommended that generators and transporters contact their receiving facilities for available participation options and costs under the new system.

Account Registration Users must register for a production RCRAInfo Industry App account (link leaves DEC's website) to sign or submit official manifests using e-Manifest. It is important to note that Pre-production RCRAInfo accounts are only used for testing purposes, will not work in Production, and cannot be used to submit real manifests to EPA.

Receiving facilities

Receiving facilities must have a RCRAInfo Industry App account (link leaves DEC's website) prior to the e-Manifest system launch. Receiving facilities who receive wastes that require the use of a hazardous waste manifest (federal hazardous wastes, state-only hazardous wastes, etc.) are required to have an EPA ID number to use the e-Manifest system, even if the facility is not obligated to have an EPA ID number under regulations.

If a receiving facility has an EPA ID number and is registered for e-Manifest, but is not available to be selected as the "designated facility" on an electronic manifest, the facility may need to be added to e-Manifest's receiving facility lookup table by DEC. In this case, the facility should contact DEC and request that their facility be added to the lookup table by sending an email to manifest@dec.ny.gov with the subject "e-Manifest: Add Facility" (the facility's EPA ID number should be included in the email).

Receiving facilities will be required to submit all final manifests to the e-Manifest system. There will be a fee for each final manifest that a receiving facility submits to the e-Manifest system and each receiving facility will be billed on a monthly basis. See the e-Manifest User Fee Rule FAQ (link leaves DEC's website) for more information. Receiving facilities accepting wastes that are state-only hazardous wastes will be required to submit final manifests to the e-Manifest system. This includes wastes that are state-only hazardous wastes in New York State or state-only hazardous wastes in the state where the waste was generated.

Transporters

Transporters must have an EPA ID number. Transporters should be identified as a Transporter of Hazardous Waste in RCRAInfo (Item 11.A.1.a. on the EPA Site ID Form 8700-12; can be updated in myRCRAid module). Transporters may verify their hazardous waste transporter activity using RCRAInfo Web (link leaves DEC's website). Transporters will need to obtain a RCRAInfo Industry App account (link leaves DEC's website) if they wish to access and sign electronic manifests using the e-Manifest system web-based submittal software. Note: Transporters of hazardous waste that pick up from or deliver to locations in New York State must have a valid Part 364 Waste Transporter permit issued by DEC. Please see DEC's Waste Transporter page for more information.

Generators

Generators will need to obtain a RCRAInfo Industry App account (link leaves DEC's website) if they wish to access and sign electronic manifests using the e-Manifest system web-based submittal software. If generators intend to meet the manifest recordkeeping requirements by storing their manifests in the e-Manifest system, they will need to obtain a RCRAInfo Industry App account and have access to their site in e-Manifest.

Completely paperless (electronic) manifesting is the lowest cost e-Manifest submittal method. If a generator wishes to use completely electronic manifests, then the generator must select a transporter and a receiving facility that are also able to use completely electronic manifests. Note: All records for completely electronic manifests will only be accessible through RCRAInfo, which requires internet connectivity.

Manifest Corrections

Users who wish to correct paper manifests may correct those manifests on paper prior to the receiving facility submitting them to EPA's e-Manifest Paper Processing Center, or electronically after the paper manifest has been submitted to e-Manifest. Paper based corrections cannot be made after a paper manifest is submitted to e-Manifest and revised paper manifests should not be mailed to EPA's e-Manifest Paper Processing Center. Users who wish to correct hybrid or electronic manifests can only correct those manifests electronically.

Beginning on September 21, 2018, electronic corrections may be made to manifests using the e-Manifest system. Manifest data may be edited before a manifest is initially e-signed and submitted to e-Manifest by the Receiving Facility. After a manifest has been e-signed, corrections may be made at any time to the manifest data using the "Make Corrections" button.

Testing (Optional)

EPA is allowing users to test early versions of the e-Manifest system and has provided information about registering test accounts and the testing process (link leaves DEC's website) on their website. *Note: Test accounts will not work with the final Production system. Anyone who wants to use the final system will be required to create another account in the RCRAInfo production system*.

e-Manifest Fee Schedule

EPA issued the Final Rule: User Fees for the E-Manifest System and Amendments to Manifest Regulations (User Fee Rule) (link leaves DEC's website) on January 3rd, 2018. This rule created the initial fee schedule for users of the e-Manifest system. The e-Manifest fees incurred by the regulated community will be based upon the method used to collect the manifest data (e.g., paper or electronic). EPA is only imposing user fees upon receiving facilities. Receiving facilities will be assessed a fee for each final manifest that they submit to the e-Manifest system and will be billed on a monthly basis. EPA will revise the fee schedule every two years to ensure that the fees charged to the regulated community reflect the cost of running the e-Manifest system. See the e-Manifest User Fee Rule FAQ (link leaves DEC's website) for more information.

FAQs

Federal:
Where can I get additional information about e-Manifest?

EPA e-Manifest General FAQ (link leaves DEC's website)
EPA e-Manifest User Fee Rule FAQ (link leaves DEC's website)

General e-Manifest questions (federal requirements, software design and development, etc.) should be directed to EPA via email sent to: eManifest@epa.gov (link leaves DEC's website).

Why can't I find my manifest in my site's e-Manifest tab in the RCRAInfo industry app?

Receiving facility staff are responsible for entering data into RCRAInfo for most paper manifests they receive and accept. If the receiving facility entered the manifest into e-Manifest and the manifest does not appear on a handler's e-Manifest tab in RCRAInfo, then it may be that an error was made when the receiving facility user entered the EPA ID number from the paper manifest into e-Manifest. If the receiving facility mailed the paper manifest to EPA for processing or only uploaded an image file of the scanned paper manifest into RCRAInfo, then it may still be awaiting processing by EPA at the Paper Processing Center. Handlers may want to consider contacting their receiving facilities for more information about their manifests. Note: Export manifests to foreign receivers are not entered into e-Manifest.

State:
Are there any additional requirements in New York State under this new system?

Yes, DEC will continue to require the following:

  • The use of all applicable state hazardous waste codes including: PCB wastes (state-only hazardous waste codes B001-B007) in 6 NYCRR 371.4(e) (link leaves DEC's website) and ultimate disposal method code (L, B, R, T) (See 6 NYCRR 372.2(b)(2)(ii) (link leaves DEC's website)).
  • Generators must continue to submit a paper copy of the generator copy of hazardous waste manifest forms to DEC if the generator uses paper or hybrid manifests to ship hazardous waste. Additionally, if a waste is exported, generators located in New York State must mail a paper copy of the manifest to DEC. DEC will evaluate the necessity of this requirement after the EPA e-Manifest system has been operating for a reasonable period of time. Generators who use the EPA e-Manifest system for entire manifest transactions (electronic manifest from the generator to the receiving facility) will not be required to submit paper copies of electronic manifest forms to DEC. Instead, DEC will have access to the manifest data in the EPA e-Manifest system.

Fact Sheets

Note: The following fact sheets are current as of June 14, 2018; any changes to federal e-Manifest requirements after that date will not be reflected in these fact sheets. Please see EPA's e-Manifest Stakeholder Fact Sheets (link leaves DEC's website) for any new or updated federal requirements. New York State requirements in the following fact sheets are current and fact sheets will be re-issued if DEC modifies New York State requirements under e-Manifest.

EPA's e-Manifest Helpdesk for Industry Users

Available: 8:00 am - 6:00 pm EST
Toll Free: (833) 501-6826
Direct Line: (970) 494-5508
Email Helpdesk for Industry Users: helpdesk@epacdx.net

Contact Information for DEC's Waste Transport and State Assistance Section

Hazardous waste manifest forms and related correspondence should be mailed to:
NYS Department of Environmental Conservation
Division of Materials Management
Waste Transport and State Assistance Section
625 Broadway
Albany, NY 12233-7252

Contact Information:
Waste Transport and State Assistance Section
Phone: (518) 402-8730
Fax: (518) 402-9024
E-Mail: manifest@dec.ny.gov

Disclaimer

e-Manifest is a federal program. The content on this page is for informational purposes only and, while believed to be accurate, should not be relied upon for official federal requirements of the e-Manifest program or legal interpretation.