Allowing Remote Signers for Electronic Manifests
In February 2023, one of EPA’s new e-manifest policies came into effect, allowing generators, transporters, and receiving facilities to execute electronic signatures through their employees or contractors who are located remotely from the hazardous waste shipment. However, the e-manifest system does conflict with DOT hazardous material regulations, which requires that a hard copy shipping paper accompany the shipment. This means double-duty paperwork for generators and transporters using the e-manifest method. It also means that you may need to look closer at your personnel involved in the hazardous waste shipment process and who is required to undergo DOT Hazardous Materials Transportation Training.
Hot items for remote signers of e-manifests:
Applies only to electronic signatures on electronic manifests conducted by generators, transporters, and the initial receipt by receiving facilities.
The final designated receiving facility is still required to submit the final electronic manifest for invoicing to the e-Manifest system via a signature method that complies with EPA’s Cross-Media Electronic Reporting Rule (CROMERR).
A Remote Signer is a registered RCRAInfo user with sufficient permissions to sign electronic manifests who is remotely located from the waste shipment. Under this policy, EPA is allowing Remote Signers to execute electronic signatures for field personnel, employees and contractors, associated with the same facility/transporter and which have first-hand knowledge of the hazardous waste shipment’s status.
Remote Signers can execute electronic signatures in the e-Manifest system through one of the following two methods:
(1) Electronically signing manifests with remote personnel through the e-Manifest user interface.
(2) Electronically signing using system-to-system communication (API).
IMPORTANT:
Currently, DOT’s hazardous materials regulations (HMR) require that a hard copy shipping paper be placed in the cab of the transport vehicle during transportation. Therefore, handlers using electronic manifests will still need to comply with DOT’s HMR requirement (e.g., print the electronic manifest from the e-Manifest system). The printed copy of the electronic manifest will reflect the names of the field personnel and remote signer. The field personnel’s name will be shown in the “Typed Name” field for Boxes 15, 17, and 20, for the generator, transporter, and receiving facility, respectively. The remote signer’s name will be shown in the “Signature” fields for Boxes 15, 17, and 20, for the generator, transporter, and receiving facility, respectively.
For Box 15 of the manifest, the Remote Signer must enter the name of the individual who is in physical proximity of the waste shipment and certifies that the wastes are properly classified, described, packaged, marked, labeled, and in proper condition for transportation according to the applicable regulations of the Department of Transportation.
This means both individuals must have the DOT Hazardous Materials Transportation Training! Both are dually certifying that the shipment is compliant with the HMR.