New EPA E-Manifest Rule Now Effective as of January 22nd
January 28, 2025
This post explores the EPA final Third Rule regarding the e-Manifest, published in July 2024, which mandates that all LQGs and SQGs register for e-Manifest as of January 22, 2025.
Q&As include:
1. What is the EPA Final Third e-Manifest rule?
2. What are the main new requirements of the e-Manifest final Third Rule?
3. Are VSQGs required to register for e-Manifest under its final Third Rule?
4. How do you register for e-Manifest?
5. What is a RCRAInfo Site Manager?
6. How do RCRAInfo Site Viewers, Preparers, and Certifiers differ from one another?
7. Where can you get advice and guidance about the EPA last Final Rule?
1. What is the EPA Final Third e-Manifest rule?
Referred to rather grandly by the EPA as its final “Third Rule” (the agency’s caps, not ours), there’s no evidence that it was delivered from a summit on stone tablets, but it is nonetheless highly consequential. And we’re betting the won’t be final. (See Q.2 ASAP!)
2. What are the main new requirements of the e-Manifest final Third Rule?
As of January 22, the EPA Final Third e-Manifest Rule 2025 commands that:
1. All LQGs and SQGs register with e-Manifest, which is to say, paper-and-pencil manifests are now verboten. Such registration is required for paying user fees, submitting manifests electronically, and submitting post-receipt corrections to manifests.
2. Transporters who wish to create and sign manifests electronically must register with e-Manifest to view them or submit corrections to them post receipt.
3. Waste management brokers must register with e-Manifest if they wish to create manifests electronically for their clients.
4. If you’re a state inspector, you’ll need to create a RCRAInfo regulatory account to view manifests and manifest data for entities conducting hazardous waste activity in your state.
3. Are VSQGs required to register for e-Manifest under its final Third Rule?
VSQGs are generally not required to register for e-Manifest, as it’s primarily designed for LQGs and SQGs. However, if your facility is a VSQG and you would like to receive final signed manifests for hazardous waste shipments, you must voluntarily register with the system.
4. How do you register for e-Manifest?
Really, it’s a piece of cake. You just…
- Sign up for a RCRAInfo account. You begin this process here, where you’ll watch the helpful User Registration Video on how to proceed.
- Confirm that your location has an EPA ID Number (aka, Site ID Number). If you need to obtain one, complete EPA Form 8700-12. (N.B. You might be able to apply for an EPA ID Number online. You can check with your state environmental agency here to see if you can.)
- Assign a Site Manager to your EPA ID. (See Q.4)
- Register additional users into RCRAInfo as needed.
- Wait for the EPA, the State, or an existing Site Manager* to approve registration.
*See Q.5
5. What is an RCRAInfo Site Manager?
Beyond viewing, editing, creating, and signing manifests and related reports, a RCRAInfo Site Manager can view & pay bills, and has access to EPA Application Programming Interfaces (APIs).
He or she can also administer permissions for other users in your company, elevating them through the ascending ranks of Viewer to Preparer to Certifier. (See Q.5)
Your Site Manager will control user registration and account maintenance for others in your organization. Until you register a Site Manager, the EPA or your individual state will administer requests for site access. So, you want to get that done ASAP. (BTW, the EPA encourages you to register at least two Site Managers for your EPA ID.)
6. How do RCRAInfo Site Viewers, Preparers, and Certifiers differ from one another?
Viewers—as you might suspect—can only view manifests in the system. Promoted to Preparers, they can also create and edit them, as well as complete non-CROMERR compliant signatures. The next level are Certifiers. They can submit manifests, complete CROMERR compliant signatures (ibid), correct manifest data, and are the highest-ups subordinate to Site Managers.
7. Where can you get advice and guidance about the EPA last Final Rule?
Environmental compliance is no simple matter. Requirements mutate and multiply while their enforcers become more assertive. And the consequences for noncompliance can be legally and monetarily significant, whether intentional or not.
Hazardous Waste Experts regulatory consultants, trainers, and subject matter experts offer you specialized expertise regarding the e-Manifest, as well as for all other hazmat compliance matters, be they big or small.
Don’t go it alone! Contact us. Or call us at our new number: 425.414.3485