Tradebe e-Manifest UPDATE

2nd UPDATE: COUNTDOWN TO EPA ELECTRONIC MANIFEST

May 11, 2018

Re: e-Manifest Launches in 50 days!

As you are aware, the United States Environmental Protection Agency (EPA) is developing a national database system for tracking hazardous waste shipments electronically, known as the "e-Manifest" database scheduled for go-live on June 30, 2018.

This update includes further information and details on:

Transporter Requirements
State Opt-In Status and Implications
RCRAInfo Registration
Technical Development Summary and Outlook

Tradebe will continue to provide updates, as well as training as this go-live date approaches. In addition, we will work closely with our clients and hazardous waste generators throughout the coming months as this new program is rolled out. The e-Manifest program will have implications for all involved. Our goal is to ensure safe and compliant shipments of hazardous waste that we manage or receive – and that our team members and clients are aware of what they need to know to remain in compliance.

Please visit our website for further details on Tradebe’s e-Manifest program including the EPA’s most Frequently Asked Questions regarding e-Manifest. For any questions or concerns regarding e-Manifest, please contact our e-Manifest team at e-manifest.faq@tradebe.com

Sincerely,

Tita LaGrimas
Executive VP of Regulatory Affairs

Transporter Requirements:

The EPA has modified the current regulations regarding the Transporter’s ability to change transporter(s) for shipments in-transit.

EPA is classifying the initial transporter’s authority that would allow them to change the transporter(s) designated on a manifest, or to add a new transporter to the manifest. A transporter may make these changes during the course of transportation of wastes; as a result to respond to an emergency, or for the purpose of transportation efficiency, convenience, or safety.

The modification to the regulations mandate a specific agreement between the generator and the initial transporter of the waste making the changes.

EPA’s Transporter classifications are a:

Transporter without agency authority; or
Transporter with agency authority.

A Transporter without agency authority:
Is a transporter without contractual authorization in place from the generator, whereas to act as an agent on behalf of the generator. Therefore the transporter must contact the generator for permission prior to making any revisions or additions to the transporter section on the manifest.

A Transporter with agency authority:
Is a transporter with contractual authorization in place from the generator, to act as the generator’s agent.

For these transporters, EPA modified the regulations so that transporters (or brokers), who intend to oversee and control the routing of the shipments on behalf of the generator, must enter the following statement in Item 14 of the manifest: ‘‘Contract retained by generator confers agency authority on initial transporter to add or substitute additional transporters on generator’s behalf.’’

It should be noted, states could pursue enforcement actions against generators for failure to produce the contract upon request as well as pursue enforcement actions against the transporters for failure to comply with adding the statement language in Item 14 of the manifest.

State Opt-In Status and Implications

e-Manifest will be implemented in all States and Territories, regardless if your State or Territory has not adopted the e-Manifest rules.

When Congress authorized the creation of an e-Manifest system, it mandated that e-Manifest would go into effect federally in all States on June 30, 2018, regardless of any State's rule adoption or authorization status. Thereafter, as States modify their respective laws to EPA's e-Manifest requirements and obtain program authorization from the EPA, the States may assume implementation and enforcement responsibilities for those parts of the e-Manifest program that are delegable to States.

It should also be noted, States may continue to collect Generator and/or Transporter’s copies of paper manifest after June 30, 2018. This includes Generator copies of any paper manifest signed by the Generator, including hybrid manifests where the Generator signs on paper. However, after e-Manifest June 30, 2018 launch, the Receiving Facility’s manifest copies may only be collected by accessing the e-Manifest National Database. States will also obtain their Receiving Facility manifest copy from the e-Manifest National Database System rather than from the Receiving Facilities.

For electronic manifests, the EPA system will collect and retain all handler copies from Generators, Transporters, and Receiving Facilities. Since States can obtain any handler copy of an electronic manifest from the e-Manifest system, States cannot require Generators or other waste handlers to supply a paper copy of said electronic manifests directly to the States.

RCRAInfo Registration

If you are a Handler and wish to view completed manifests that have been submitted to the EPA by a TSDF, you will need to register: RCRAinfo registration

To learn more, please register for the EPA Learning Zen and watch the video instructions. Choose the 7 chapter course 'Industry User Registration’ - this course takes about 30 minutes to complete. Within the RCRAInfo system, a user can be assigned different permission levels as shown in this training course.

Tradebe recommends that care is given to the assignment of permission levels within your organization in advance of the e-Manifest June 30, 2018 launch.

Technical Development Summary and Outlook

The EPA is currently focused on completing the e-Manifest functionality for Receiving TSDFs. Certain functionality, especially for Brokers, ‘on behalf of’ Agents and correction activities will only become available after the launch of the e-Manifest system. Please also be aware that depending on the four different types of e-Manifest submitted, the available functionality for each will vary.

Details can be found in the latest EPA Webinar recording.

50 Days until Launch ~
ARE YOU READY FOR E-MANIFEST?

If you took our first e-Manifest survey, thank you!

Please take a few minutes to respond again to our Updated Survey below so that we may continue to understand your needs and deliver the information that matters to you regarding this new program.

Take our e-Manifest Survey Now!

About Tradebe

Tradebe is a $500MM global company in the environmental sector serving various markets including industrial, manufacturing, petrochemical, pharmaceutical, oil & gas and more - leading industrial waste management services in Europe (UK, Spain and France), the Middle East and in the US. Tradebe, employing more than 2,100 people worldwide, operates 77 facilities across Spain (25), United Kingdom (20), United States (23), France (2); and the Middle East, Oman (7). www.tradebe.com

In the United States, Tradebe’s network of facilities includes fully permitted TSDFs and regional 10-day service centers positioned throughout the country. We maintain a fully permitted transportation fleet operating throughout this network to service our clients’ diverse transport requirements.

We recycle over 60% of the waste we process. As a global business dedicated to sustainable waste management, we seek the greenest waste solutions possible with a priority on recycling and recovery.
For more information on how Tradebe can assist you with your goals of sustainable waste recycling,
please call us at (800) 388-7242 Nationwide or email us at sustainability@tradebe.com or www.tradebeusa.com

Need more information? Contact us!
Tradebe Environmental Services, LLC
1433 E 83^rd Ave, Suite 200
Merrillville, IN 46410
(800) 388-7242
us.salesinfo@tradebe.com
www.tradebeusa.com

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