As a waste generator, you have a vested interest in how your facility’s waste is disposed of and how that process impacts your bottom line.
Finding a sustainable solution that minimizes any associated costs can be difficult, especially when certain wastes must be transported long distances to satisfy any federal and state disposal regulations.
One of the costs often associated with waste removal is the manifest fee. In 2018, the Environmental Protection Agency began implementing a national e-manifest system that electronically tracks hazardous waste shipments. As part of this system, the EPA charges user fees that receiving facilities must pay for each manifest submitted.
With any new system put into place - especially in heavily regulated areas such as hazardous waste transportation and disposal - there’s always some confusion about who is responsible for associated costs, whether it’s the generator, transporter or receiver.
Below are some common questions we are asked by waste generators about the e-manifest system and its required fees.
How Does The E-Manifest System Work?
For several decades, the EPA has imposed a manifest system that tracks cradle-to-grave hazardous waste as a way to control the waste from the time it is generated to its final disposal.
Recently, however, the manifest system began the transition to an electronic format to save time, resources and costs. The electronic database runs through the EPA’s Resource Conservation and Recovery Act (RCRA) info website.
The e-manifest system allows generators and transporters to create, edit and sign manifests. They also are easily able to retrieve copies and status information on manifests.
Receiving facilities sign the manifests when the waste is received, are able to submit them to the EPA and can make any necessary corrections to already-submitted manifests. Data in the e-Manifest system also is accessible to the general public through a separate website interface.
What Is A Manifest Fee?
To help fund this system, the EPA charges user fees to receiving facilities for every manifest that is submitted. The amount of that fee is determined by the method by which the EPA receives the manifest.
The EPA is encouraging hazardous waste generators to utilize electronic manifesting so that all industry members can take advantage of the cost savings it provides. That’s why the EPA has set a cost lower for submitting manifests electronically than submitting a paper version.
Through September 2019, the costs for submitting a manifest are as follows:
- Mailed in paper manifest: $15
- Scanned image uploaded: $10
- Data and image upload: $6.50
- Electronic manifest (fully electronic manifesting): $5
Fees may change on an annual basis and as the new manifest program evolves. The EPA’s e-Manifest User Fees and Payment Information page provides up-to-date costs each year.
It’s important to note that the EPA does not charge user fees to generators, transporters or brokers. Therefore, if your company sends your waste to Temarry, there are no manifest fees to be passed on to the generator, broker or transporter. There are no manifest fees charged to Temarry by the EPA because our processing facility is not located in the United States. EPA cannot levy fees, taxes or fines outside of the U.S.
What Can Impact The Fees?
Some manifests may incur greater costs to process, depending on the mode of submission. These manifests may incur additional fees, according to the EPA.
If a waste is rejected, the receiving facility also will be responsible for any additional fees incurred by the rejected waste.
As mentioned above, the amount of the fees may change over time. According to the EPA, the fees are dependent upon the program costs. When revising its fee schedule, the EPA will examine recent manifest data and any other associated program costs, as well as inflation factors.
The e-Manifest Advisory Board, as well as the Office of Inspector General, provide independent oversight of these user fees and any subsequent changes.
Why Is A Manifest Necessary?
After several high-profile environmental disasters occurred in the 1960s and 1970s, the United States instituted several federal environmental statutes, including the creation of the RCRA.
With more solid waste generation, rising costs and less disposal capacity issues plaguing the waste management system, lawmakers began developing strategies to protect the environment in cost-effective ways. The development of a manifest system helped regulators track waste and manage it effectively, from the moment it was generated to the moment it was disposed.
To help address many challenges that continue today, including the need to reduce costs associated with the manifest system, the EPA began the process to convert the current manifest system to an electronic format.
How Do I Choose A Disposal Method?
Although your company will not be required to pay any associated manifest fees when working with Temarry Recycling, you will receive other benefits as well that ensure you comply with federal and state standards in a cost effective manner.
Temarry utilizes their own transportation assets to move waste from the broker to the Temarry processing facility for complete cradle-to-grave services. Temarry’s services include:
- Retrieving clean, usable solvents from liquid waste products by distillation.
- Reducing or completely eliminating solid hazardous wastes through our Waste to Energy thermal treatment system. This system uses valuable energy generated from solid hazardous waste.
Offering the highest level of sustainability, the Temarry process recovers expensive solvents and returns them back into industry for reuse. This eliminates the need for costly disposal or inefficient fuel blending. Temarry is one of only a few facilities that can recycle flammable liquids for reuse, ensuring your waste is disposed of more cost effectively and more environmentally friendly.
Temarry Recycling service includes transporting hazardous waste to our facility in Tecate, Baja Calif, Mexico, meeting all of the legal requirements including RCRA, Non-RCRA and non-hazardous waste. As part of the manifest export process, as a generator, your liability ends when the waste crosses the Mexican border.
Want to know why companies like yours are enlisting Temarry to transport their waste to Mexico? Our article, The Top 5 Benefits Of Sending Hazardous Waste To Mexico For Recycling, addresses how it reduces your liability, reduces the amount of paperwork necessary and improves your company’s sustainability practices.