On Monday, the United States Environmental Protection Agency (“EPA”) issued a Compliance Advisory Update announcing the implementation of streamlined changes to the Hazardous Waste Manifest submission process.  Pursuant to the Hazardous Waste Electronic Manifest Establishment Act, beginning on June 30, 2018, EPA will launch a new e-Manifest system nationwide, allowing Hazardous Waste Manifests to be created and submitted via the EPA website. Consequently, EPA will no longer be accepting paper manifests and paper manifests submitted to the New Jersey Department of Environmental Protection will not be forwarded to EPA.

Among those most impacted will be treatment, storage, and disposal facilities (“TSDs”) which receive and report hazardous waste to EPA. The e-Manifest system will not be required for very small quantity generators (“VSQGs”), medical waste generators, used oil generators, universal waste generators, and others who are not required to have an EPA ID nor use the uniform hazardous waste manifest (EPA Form 8700-22).

To avoid confusion over compliance as the new e-Manifest system launches, EPA will phase in the rule based 30 day deadline such that all manifests expected to be delivered to EPA between June 30 and September 1, 2018 may be submitted to EPA as late as September 30, 2018.  More information on the e-Manifest system is available via the EPA website.