What is the e-Manifest system, how do you to register for it, and how can this technology make the hazardous waste shipment process easier?
By Michael Bryant

The EPA e-Manifest System was launched in 2018, and some waste generators and service providers have already climbed onboard with the program. The EPA established the e-Manifest System according to the Hazardous Waste Electronic Manifest Establishment Act, which became law in 2012. This legislation authorizes the EPA to implement a national electronic manifest system to electronically track hazardous waste shipments. The cost of developing and operating the system is covered by user fees charged to those who use hazardous waste manifests. Last year the Environmental Protection Agency (EPA) expected to receive more than 2 million waste manifests. However, due to a slow adoption of the e-Manifest system, the agency anticipated only about 1 percent of those would be fully electronic e-Manifests.

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The PegEx® Platform provides a complete e-Manifest workflow.

Despite the slow adoption of the e-Manifest System, the EPA is taking measures to improve compliance, by implementing higher fees for mailed paper manifests. The deadline for full compliance has been set for the summer of 2021, at which point the EPA is certain to implement more stringent methods to improve compliance.

One of the things that has been a “pain point” in the adoption of the e-Manifest system for many in the industry is the difficulty involved in electronically signing the document. The EPA is planning a virtual public meeting to be held online and over the phone on the Hazardous Waste Electronic System (e-Manifest) Advisory Board from April 14 – 16. The issue of electronic signatures will be a main topic of that meeting while the theme will be “Reengineering Electronic Signatures for Generators and Transporters to Increase Adoption of Electronic Manifests”. Three different methods will be explored to improve this process.

#1: Site Manager
The first method is to require at least one person (per respective generator and transporter) to become registered in the EPA’s RCRAInfo system as a “Site Manager.” Under this method, the Site Manager would identify/confirm/update the specific personnel (e.g., employee on the loading dock, driver) on the electronic manifest who will have firsthand knowledge of the manifest shipment. This person will be responsible for electronically signing the generator certification or transporter acknowledgment of receipt by identifying, confirming and updating the name, phone number or e-mail address associated with that name. The system would then send a link to the phone number or e-mail of the individual employee. The assigned person will then simply click a link, found in the text or e-mail, to electronically sign the e-Manifest.

#2: Preparers
A second method is to require at least one person to become registered in EPA’s RCRAInfo system as a “Site Manager” for their respective sites. That person will then have all other personnel become registered as “Preparers”. These personnel would receive a username and password using the current registration process and would then request access to their site, as appropriate, but would not need to undergo further identity proofing. Generator and transporter personnel that are registered could then log in with their username/password and create and edit electronic manifests. Electronic signatures under this method would consist of logging in and clicking a button to electronically sign.

howtosidebar#3: Digitized Signature Pads
A third method is to use digitized signature pads that have been approved by the Agency under its Cross-Media Electronic Reporting Rule (CROMERR) program. This method would require generators and transporters to possess signature pads that allow them to record their signature electronically, for example, using a stylus. So, progress is being made on this front and perhaps even a solution will come out of the April meeting.

Using Waste Management Software for e-Manifest Preparation
One of the biggest complaints about the e-Manifest is that it is complicated to use. Also, just because it is electronic does not mean errors cannot happen in preparing the manifest. Waste management software solves both problems as it makes generating and filing manifests easier and more accurate.
Waste management software falls under a general category of Software-as-a-Service or SaaS. These tools are designed to optimize any number of waste business operations. Companies in every sector have been adopting these tools to save time, resources and generate more revenue.

Waste Management Software Advantages
Preparing a waste manifest takes time. Waste management software makes it easier by allowing users to point and click to quickly complete many form fields instead of typing out information. This also improves accuracy as many typos are eliminated. As the waste manifest takes less time to create, work teams are free to complete other tasks. Also, the software makes it easier to train new hires to complete these forms, especially since people are more tech savvy today than ever.
Some waste management software solutions even allow you to directly link to the e-Manifest System via the EPA RCRAInfo Portal. This puts the entire process under one platform for maximum efficiency.

What Did You Say About Revenue Generation?
Having the waste manifest tool as part of a larger package called waste management software has many advantages. These powerful platforms open a wide range of opportunities for waste companies to improve operations and grow their business. For instance, the sales management component allows you to:
• Manage business with real-time updates of all business-critical functions
•  Visualize all sales opportunities at a glance
• Leverage a variety of sales team management tools
• See real-time job status updates
Also, the customer management component makes sure you retain customers and meet their needs. Remember, it can cost five times more to attract a new customer versus retaining a current one.

This Same Technology Can Serve Other Business Forms
Even though only waste manifests are under e-Manifest System requirements, waste service companies are constantly filling out forms. In a regulated environment, the accuracy of these forms is imperative. From a business point of view, the time it takes to complete these forms is critical as well. Just like the waste manifest, many other forms can be generated by waste management software, such as:
• Waste profiles
• Quotes
• Biennial EPA reports
• Hazardous Waste Labels

Plus, other documents can be stored online in the software’s data repository such as Safety Data Sheets, EPA ID number applications, permits, quotes, licenses, contracts, work orders, certificates of destruction and more.
The other benefit is that all these archived documents are stored in the cloud, so they can be accessed from any device with an Internet connection. There is no special hardware required, and it also provides a level of security against fire or natural disaster.

SaaS Trending
The e-Manifest is simply a manifestation of an overall trend towards digitization of not only regulated documents, but also of overall business functions. In the past, technological updates meant weeks, if not months, of meticulous planning to install servers and hardware on-premise.
Today, the installation of software is much more agile and requires no special hardware at all. Deployment time is often reduced to days. Also, system updates are automatic and do not require an IT team as the SaaS provider does the tweaking.

Waste Management Software
For waste management companies, the best solutions are created by those with firsthand knowledge in the waste sector. This helps to make sure compliance is spot on and that the nuances of the waste business are appropriately addressed. The end result is better business operations, improved customer satisfaction and new revenue streams.
Adopting the e-Manifest system has the benefits of cost savings, better record-keeping and risk mitigation. Adopting a cloud-based waste management system that has an e-Manifest component offers even more benefits across your entire operation. | WA

Michael Bryant is Director of Marketing for PegEx, Inc. (Fitchburg, WI), Hazardous Waste Experts. He is part of a team that has more than 130 years of combined waste industry experience. Michael can be reached at michael.bryant@pegex.com. For more information about how PegEx can help you get on board with the e-Manifest system, streamline your business and stay in regulatory compliance with all interested federal, state and local agencies, visit www.PegEx.com. ©2020 PegEx, Inc.

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