Veolia's approach to implementation of the e-Manifest system is as follows:
- Hazardous waste shipments managed by Veolia will comply with EPA's e-Manifest system and associated regulations by the 6/30/18 compliance date.
- Veolia, having representation on EPA's e-Manifest Advisory Board, has been and continues to work closely with EPA to develop a workable e-Manifest solution.
- Veolia has reviewed EPA's recently published User Fee Rule and work is now underway to make the necessary programming modifications to its existing manifesting and waste tracking systems to integrate with EPA's e-Manifest system. At this time EPA has a significant amount of design and programming work remaining to complete as well as some key policy decisions pending that directly impact the ability for existing business systems to effectively interact with the e-Manifest system. EPA's timing in completing these tasks may impact the hazardous waste management services industry's ability to have business systems modified and prepared to for full e-Manifest use by 6/30/18.
- During this transition to an electronic system for manifesting wastes, Veolia will continue to offer its customers who may not be initially prepared to initiate an electronic shipment or have a preference to continue with paper manifest the option to use a paper manifest. Regardless of the type of manifest initiated at Veolia's customer's site (paper or electronic), all manifests following acceptance by Veolia's receiving facilities will be transmitted to EPA in an electronic manner.
- Veolia does not intend to submit paper manifests to EPA after 6/30/18. In the case of of paper manifest received, manifests data will be electronically transmitted to EPA as a data file with an image upload. EPA has estimated manifest transaction fee for this type of submittal will be approximately $7 per manifest. For those manifests accepted at the receiving facility as an electronic manifest, the data will be forwarded on to EPA as electronic data, with EPA estimating the transaction fee to be approximatley $4 per manifest. According to EPA's final User Fee Rule, the receiving facility will be billed by EPA the manifest transaction fees. The decision as to what if any manifest transaction fees will be assessed to Veolia's customers based on manifest activity will be determined at a later date.
- Once a fully functioning e-Manifest system is available for use Veolia will provide further guidance and instruction to its customers for registering and obtaining an account in the e-Manifest system. As more information becomes available, we will communicate our progress on the implementation of EPA's e-Manifest program. For additional inquiries, please contact your local Account Management team.