CHANGES IN EPA HAZARDOUS WASTE GENERATOR REPORTING

E-MANIFEST REGISTRATION

FYI and better late than never, EPA published the e-Manifest final rule on July 26, 2024, that impacts small and large quantity generators (SQG and LQG) regarding manifest regulations for shipments of hazardous waste and polychlorinated biphenyls that are transported for treatment, storage, and disposal.

Remember a SQG generates more than 220 pounds of hazardous waste per month.  A LQG generates 2,200 pounds of hazardous waste per month.  Generator status changes monthly!

Small and large quantity generators were required to register for e-Manifest by January 22, 2025.  E-manifest is EPAs electronic manifest system and is located at: The Hazardous Waste Electronic Manifest (e-Manifest) System | US EPA.  Once registered you are required to maintain an account with Site Manager or e-Manifest Certifier permissions to meet the new regulatory changes. 

Treatment, Storage and Disposal Facilities no longer have to mail a copy of the manifest to LQGs and SQGs after January 22, 2025.

EPA recommends requesting Site Manager access for your EPA ID. A Site Manager is a specialpermission to view, edit, create, sign and correct manifests and manifest-related reports. Site Managers also administer permissions for other users in their organization and may also administer the ID and Key for using the Application Programming Interfaces (APIs).

BIENNIAL REPORTS AND RE-APPLICATION FOR EPA ID NUMBERS BY LQG AND SQG

EPA has also revised some requirements related to biennial reports and EPA ID numbers.

 Any generator who was a LQG for even one month in an odd numbered year, must submit a biennial report using EPA Form 8700-13A/B.  It provides details about the types, quantities, and how it was managed during the reporting year.  Additionally, the LQG must re-notify EPA about site activities by submitting the EPA Site ID Form (8700-12) with the biennial report.  EPA Forms 8700-12, 8700-13A/B, 8700-23 were recently revised

SQGs must re-notity EPA about site activities every 4 years.