EPA’s New Electronic Hazardous Waste Manifest Requirements

By: Stericycle

New EPA regulations related to electronic manifesting of hazardous waste will take effect later this year.  These new E-manifest requirements will apply to all hazardous waste pick-ups performed June 30 and later and require hazardous waste Treatment, Storage and Disposal Facilities (TSDFs) to submit manifest data to EPA for the shipments they receive.  The EPA will maintain this data in a publicly accessible E-manifest system and invoice TSDFs a per-manifest fee to fund development and upkeep.

Stericycle is prepared to comply with all new data submission requirements related to E-manifest.  Here is an overview of Stericycle’s approach to compliance with these new regulations and some links to key resources with additional information:

  • Several key details about the logistics of the E-manifest data submission process and the associated fee structure remain pending from EPA, including the per-manifest fee structure.
  • The current provisional fee structure ranges from $4 to $20 per manifest depending on how the data is submitted to EPA by the TSDF.
  • EPA currently plans to publish the final E-manifest fee structure by early April.
  • At this time, Stericycle anticipates that there will be no change to the current service process. All hazardous waste shipments will continue to be documented on paper manifests, and Stericycle will submit the required data to EPA for those manifests received at our TSDFs.
  • We continue to work closely with EPA to evaluate options for transitioning to a fully electronic manifest. However, this transition will require complying with detailed software signature requirements that have not yet been fully vetted by EPA.  As such, Stericycle will not be moving forward with full electronic manifesting until a clear software solution is in place that will meet all EPA requirements and protect the security of our customers and their manifest data.
  • DOT will continue to require paper shipping documents until/unless the hazmat regulations in 49 CFR are amended to more closely align with EPA.
  • Stericycle has assembled a working project team to manage communication, training and documentation related to the new E-manifest requirements. Stericycle is in the process of assessing projected costs to Stericycle and impact to our customers.
  • Stericycle is monitoring the EPA’s E-manifest communications for new developments and will share these with our customers as they become available. We will plan to circulate another update in mid-April once the proposed manifest fee structure has been finalized.
  • While we are committed to complying fully with revised regulations in the most efficient manner feasible, E-manifest regulations will create additional operating expenses for Stericycle that are not part of current service offerings.  In order to account for these operational changes, we will be reaching out to our customers in April to discuss E-manifest fees.
  • To learn more from EPA about E-manifest regulations, click here
  • The EPA’s E-Manifest Project Team has shared a FAQ’s document (see attached), and has additional answers posted on the E-manifest website:

To submit a question to Stericycle about E-manifest regulations, click here.