More manifest changes incoming in 2025!
On June 28th, 2024, the Environmental Protection Agency (EPA) signed the “Third Rule” related to e-Manifest reporting. The rule takes affect on January 22, 2025, so get ready!
Here are some of the relevant rule changes for domestic shipments of hazardous waste:
RCRAInfo Portal Requirements for LQGs & SQGs
Large and small quantity generators of hazardous waste will now be required to create online accounts in the RCRAInfo Portal. Final signed copies of waste manifests will now be made available via the e-Manifest system, versus a final manifest hard copy being mailed back to the generator.
The receiving facility is now required to always submit the top copy of the paper manifest and any continuation sheets to the e-Manifest system.
Other manifest-related reports to be incorporated into the e-Manifest system include Exception (manifests from receiver are late), Discrepancy (quantity or type of material does not match received manifest), and Unmanifested Waste (waste arrives at facility with no manifest) Reports.
Timelines for Exceptions Reporting & Discrepancy Reporting
For Exceptions Reporting for LQGs, the 35/45-day timeframes will be adjusted to 40/50-day timeframes. Facilities will now be allowed 40 days to verify receipt of shipment and must file an exceptions report within 50 days if the manifest is not sent by the 40th.
For Exceptions Reporting for SQGs, the 60-day timeframe will not change.
For Discrepancy Reports, the 15-day reporting timeframe will be changed to allow receiving facilities up to 20 days to reconcile a shipment with the transporter or generator if a discrepancy is found.
TSCA PCB Regulation Updates
The EPA is proposing to add the Hazardous Waste Electronic Manifest Establishment Act to the Authority section for 40 CFR part 761, as well as to add definitions and an overview of e-Manifest reporting to PCB regulations.
The Third Rule would also make corrections and conforming changes to align the requirements for manifesting PCB waste shipments with the e-Manifest requirements.
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