Resource Conservation and Recovery Act Hazardous Waste Manifest System: February 8th U.S. EPA Federal Register Notice Addressing Information Collection

February 12, 2019

By: Walter G. Wright

Category: Arkansas Environmental, Energy, and Water Law

Download PDF

The United States Environmental Protection Agency (“EPA”) published a February 8th Federal Register Notice addressing the federal agency’s plan to submit an Information Collection Request (“ICR”) addressing:

. . . Requirements for Generators, Transporters, and Waste Management Facilities Under the RCRA Hazardous Waste Manifest System.

See 84 Fed. 2854.

The ICR is a proposed extension of one which is currently approved through May 31, 2019.

EPA is soliciting public comments on specific aspects of the proposed ICR. It states it is proposing and soliciting comments and information to:

  1. Improve the precision of waste quantities and units of measure reported in items 11 and 12 of the Hazardous Waste Manifest (both paper and electronic);
  2. Enhance the quality of international shipment data reported on the manifest
  3. Assist EPA with integrating e-Manifest and biennial reporting requirements

EPA states it is proposing several improvements/enhancements regarding the Resource Conservation and Recovery Act Hazardous Waste Manifest System. The issues addressed include:

  • Improving precision of waste quantities and units of measure
    • Use of decimals (proposal to modify the manifest instructions to Item 11 of the manifest to grant manifest users the option to report waste quantities using decimals or fractions)
    • Alternative set of units of measure (addition/alternative to using decimals or fractions or precisely report waste quantity by also using smaller units of measure)
  • Enhance quality of international shipment data
    • Addition of a new data field for consent numbers for import and export shipments (proposal to add a new data field on the paper and electronic manifest so hazardous waste stream consent numbers can be recorded in a separate, distinct field on a manifest)
    • Capturing exporter EPA ID number on the manifest
    • How to incorporate new fields on manifest and whether to consolidate with movement document
  • Biennial reporting and e-Manifest integration

A copy of the Federal Register notice can be found here.

The Between the Lines blog is made available by Mitchell Williams Law Firm and the law firm publisher. The blog site is for educational purposes only, as well as to give general information and a general understanding of the law. This blog is not intended to provide specific legal advice. Use of this blog site does not create an attorney client relationship between you and Mitchell Williams or the blog site publisher. The Between the Lines blog site should not be used as a substitute for legal advice from a licensed professional attorney in your state.