June 30, 2018 is the effective date for EPA’s Hazardous Waste Electronic Manifest System (e-Manifest), but at that time nothing will change for you. Just this week, EPA launched a special software testing event, 60 days before the actual go-live date. Heritage will be participating in this testing event.
After reviewing the compliance options and considering that the e-Manifest system is still in active development by EPA, Heritage will continue to provide paper manifests after the effective date. We will upload the electronic data from our systems within 30 days of acceptance. We consider this course of action as the most stable, safe, and compliant. This process is identical to current manifest practices, and will not require any additional actions by our customers or transporters.
Heritage will migrate to a fully electronic e-Manifest when we are confident that we can provide an excellent customer experience. At that point, Heritage will provide outreach and multiple training opportunities.
As mentioned above, no new actions are required for a paper manifest process. However, e-Manifest registration is strongly recommended and does offer several benefits. In particular, registration will allow customers to see all (paper) manifest data as soon as it has been uploaded by Heritage.
There are different user roles in the e-Manifest system. The most important one is a company administrator role called a “Site Manager.” This role has increased capabilities, such as the ability to administer other user accounts at your company (functionality not yet available), e-sign and correct manifests, plus assign broker and “on behalf of” signature privileges (functionality not yet available).
EPA and Heritage are encouraging generators to register at least two Site Managers per location. If you want to “test drive” the e-Manifest today, you can do this but must register in EPA’s test system. After the rule’s effective date, you will need to be registered in the production e-Manifest system. Registration in the test system does not transfer to the production system. As of the time of this email, only select states are allowing registration for the Site Manager role in the production system. Additionally, EPA’s current policy is that every individual that signs a paper manifest would need to be registered to electronically sign an e-Manifest.
The EPA has prepared a list of questions and answers to many common questions. We hope to highlight some of these FAQs in our May e-Manifest update. Click the button below to go to the EPA e-Manifest FAQ web page:
To read our original 3/6/18 message on the EPA’s e-Manifest Launch, go to: https://www.heritagewastesolutions.com/e-manifest-update/
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