The Environmental Protection Agency (EPA) has announced that it will soon be conducting tests on the Internet of a system that would prepare and transmit the Resource Conservation and Recovery Act (RCRA) hazardous waste manifest electronically.
Tests will be conducted primarily in New York and Pennsylvania in late 1999, under the auspices of the Manifest Automation Pilot project.
The Manifest Automation Pilot is a joint effort sponsored by EPA's Office of Solid Waste and the Office of Policy. The pilot project is designed to make the process of tracking hazardous waste faster and more efficient through the use of electronic systems. The project is consistent with the Regulatory Reinvention Initiative and the Paperwork Elimination Act of 1998, which call for government to reduce paperwork burdens and to move toward automated reporting practices, according to EPA.
The pilot project also supports efforts underway at EPA to develop revisions to the hazardous waste manifest system, and in particular, to develop regulatory standards for automating the manifest.
The key component of the paper-based hazardous waste manifest system is the Uniform Hazardous Waste Manifest. The manifest report is required by all generators that transport, or offer for transport, hazardous waste for off-site treatment, recycling, storage, or disposal.
Multiple Copies Currently, the manifest is a paper document consisting of multiple copies that accompany waste shipments while they are in transportation. It contains information on the types and quantities of hazardous wastes being transported, information about the generator, transporters, and facilities that will manage the waste, and signature lines for all parties involved with the shipment. The manifest is required under both Department of Transportation regulations addressing hazardous materials and RCRA regulations for hazardous waste transportation.
All of the parties that handle the waste sign the manifest and retain a copy for their records. This ensures critical accountability in the transportation and disposal processes.
Once the waste reaches its destination, the receiving facility returns a signed copy of the manifest to the generator, confirming that the waste has been received by the designated facility.
However, the use of the current paper-based system entails much paperwork and data processing burden both for the waste facilities that must complete the paper forms, and for the state agencies that receive manifest copies and track manifest data. Ideally, an electronic system could reduce these paperwork burdens and improve the EPA's ability to track hazardous waste shipments and data.
Five Objectives EPA has five primary objectives for the Manifest Pilot tests:
(1) Demonstrate the feasibility of using Electronic Data Interchange (EDI) and an Internet forms-based approach to track waste shipments in a secure, legal, and practical manner.
(2) Evaluate the savings and costs associated with a fully automated system.
(3) Facilitate the development of standards to include in the manifest revisions rulemaking.
(4) Demonstrate the feasibility of automating the entire manifest transmission cycle, including preparation of the manifest, transmission of copies to other waste handlers, and reporting of manifests to states.
(5) Identify and resolve impediments to the automation of the manifest. The Manifest Automation Pilot project has three main test phases: a basic EDI approach (completed in December 1998); a digital signature test (now underway) integrated with the Phase 1 EDI approach; and an Internet forms/electronic signature approach. The first and second phase EDI tests involved waste handlers and state agencies in the states of Illinois, Indiana, and Minnesota.
EPA and environmental agencies in New York and Pennsylvania are now recruiting industry volunteers to participate in the Phase Three Pilot test. This will be strictly a web-based pilot test involving state agency personnel, EPA representatives, and RCRA generators, transporters, and storage and treatment facilities (TSDFs) interested in helping the EPA to demonstrate if the waste tracking functions of the manifest can be accomplished on the Internet. Pilot participants will be able to access a web-based hazardous waste manifest form in which nearly all aspects of the paper-based process, including electronic signatures, can be addressed and improved.
Software Loan EPA will loan participants the software and hardware (digitizer pads and electronic pens) necessary for the Internet tests. Technical support (including on-site support if needed) will be provided to participants by an EPA contractor, DPRA Inc, based in Rosslyn, Virginia. Once the participants are identified, EPA will schedule planning meetings and distribute test schedules and other information about the tests.
Meetings generally will occur by conference call. Participants will need to provide a dedicated personal computer running Windows 95 or Windows 98, with Internet access and an open serial port for the digitizers. Participants also will need to designate a staff contact who can dedicate about two hours per week for the four-month period that is expected to be required for setting up and running the tests.
Tests are expected to begin in late October or November 1999. Once underway, the Internet pilots will run for approximately three months.
Participants in these tests still will have to prepare the normal paper manifests for all waste shipments they handle during the period of the pilot tests. EPA cannot excuse compliance with the paper system until the rules are changed to allow electronic manifest transmissions.
Further information about these tests is available from Richard LaShier, EPA, Office of Solid Waste 703-308-8796 or check out the web site at www.epa.gov/osw.