New Policy Brings Hazardous Waste Management Closer to 100% Electronic Manifest

On May 5, 2023, the U.S. Environmental Protection Agency (EPA) issued a memorandum communicating their new policy on electronic manifest (e-Manifest) signature permissions. The policy—which has been in effect since Feb. 10, 2023—allows remote employees of generators, transporters, and receiving facilities of hazardous waste to complete electronic signatures on manifests in place of onsite personnel.

This memorandum is only applicable to hazardous waste manifests that begin electronically. This means that if a paper manifest is uploaded to the e-Manifest system, it must still be signed with a wet ink signature prior to upload.

How to Provide an Electronic Signature

Remote employees can electronically sign through one of two channels:

For those choosing to use the e-Manifest user interface, field personnel physically responsible for the waste shipment must directly authorize a remote employee to complete their electronic signature.

According to the policy, the Remote Signer must be registered in RCRAInfo and have the appropriate access to execute signatures in the e-Manifest system. Once access has been confirmed, both the field personnel physically responsible for the waste and the Remote Signer’s names are needed on the electronic manifest.

Taking Advantage of the Remote Signer Policy

The Remote Signer policy will be beneficial for circumstances where field personnel have limited or no network access to create an electronic manifest, and it can reduce the number of personnel required to obtain access to RCRAInfo. By providing more flexibility, the EPA hopes to increase participation in the e-Manifest system as they work toward their goal of 100% electronic manifests.

APTIM works closely with hazardous waste generators utilizing the e-Manifest system to ensure compliance and continuously improve program efficiency. If you think this policy may be beneficial to you, APTIM representatives can assist in adapting to and effectively using the e-Manifest system.

For more information, the public docket for the Hazardous Waste e-Manifest Advisory Board meeting on this memorandum can be found at Regulations.gov.

Contact
Rachel Newton
Environmental Scientist
Rachel.Newton@APTIM.com