Another costly federal computer system is in the works. California companies need to be aware of changes to the current hazardous waste manifest system and prepare for a new set of fees, and potential business infrastructure upgrades to be in compliance.
The U.S. Environmental Protection Agency (EPA) took steps last week to take the tracking of hazardous waste into the 21st century. On January 15, 2014, the agency issues a final rule that it says is “a crucial step in the development of a national electronic manifest (e-manifest) system which will upgrade the current paper-based system of tracking hazardous waste to an electronic one.” (Source: epa.gov)
“The final rule authorizes the use of e-Manifests to track hazardous wastes under the Resource Conservation and Recovery Act. This will allow the current process, which requires paper forms, to be streamlined and greatly reduce the millions of paper manifests produced each year. “
Historically the tracking of hazardous waste is handled by state and local governments such as the California Department of Toxic Substances Control, which has come under criticism by watchdog groups for the antiquated way that it handles toxic substances.
The Lost Loads of California
The California regulatory agency came under fire late last year when a Los Angeles Times expose revealed that the agency (DTSC) has lost track of 174,000 tons of hazardous material shipped for disposal in the last five years, more than 23,000 truck or tanker loads. As reported in the Times article much of the blame for this problem was attributed to the antiquated paper system that the agency was forced to utilize. The loss of potentially hazardous chemicals and materials sitting unchecked or dumped necessitates a more sophisticated tracking system.
Public Safety
One of the primary motivations is to increase access to information for first responders at chemical spills and hazardous cleanup situations. “Once fully implemented, the national e-Manifest system will provide greater access for emergency responders to information about the types and sources of hazardous waste that are in transit between generator sites and waste management facilities,” as indicated in the EPA press release.
The authority to create the “e-manifest” system was granted to the EPA by the “Hazardous Waste electronic Manifest Establishment Act signed into law by President Obama on October 5, 2012. “The Hazardous Waste Electronic Manifest Establishment Act requires EPA to issue a regulation authorizing the use of electronic manifests as the legal equivalent of the current paper manifest forms used to track shipments of hazardous waste from a generator’s site to the ultimate site of disposal. EPA’s goal is to promote the greatest possible use of electronic manifests.”
Impact on California Businesses
“The e-Manifest program is the vanguard of the agency-wide initiative to develop new tools to reduce the reporting burden on regulated entities, and provide the agency, states and the public with easier access to environmental data. EPA estimates the national e-Manifest system will ultimately reduce the burden associated with preparing shipping manifests by between 300,000 and 700,000 hours, and result in cost savings of more than $75 million per year for states and industry.”
The federal agency will begin discussions immediately with stakeholders including state and local governments and members of industry.
A new system will be costly to implement, so hazardous waste generators should prepare themselves for a new set of fees, although no cost estimates have been revealed as of yet.
The cost to implement at least on paper should be offset over time by the man hours needed to oversee the cost of dealing with the current antiquated system, so businesses could see a benefit in decreased overhead over time, however with any new system, there will be a cost to implementation. Please subscribe to our blog to continue to receive updates as these new change unfold.
Let’s hope this federal system runs smoother than the rollout of the “Affordable Health Care Act.” We could see changes to the system as early as next year.
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