In case you didn’t know, USEPA has been striving for some years now to put in place an electronic system for the transportation in commerce of a hazardous waste. Currently, all regulated shipments of a hazardous waste must be documented on and accompanied by the Uniform Hazardous Waste Manifest. This will change with the implementation (June 2018! Read all about it: Learn About the Hazardous Waste Electronic Manifest System or e-Manifest) of the electronic manifest system (e-Manifest).
A question I received recently was this:
How is the driver/transporter expected to e-sign the manifest? Is the expectation that they will access the document electronically at the generators site and somehow e-sign there? Or, have equipment of their own to do so?
My answer comes right from the regulations USEPA created for the e-Manifest:
USEPA regulations at 40 CFR 263.20(a)(5) indicate that access to the e-Manifest system by a transporter can be through the transporter’s own electronic equipment or by accessing the equipment provided by the generator, by another transporter, or by a designated facility.
In short, any person involved in the “cradle-to-grave” management of the hazardous waste participating in the e-Manifest system can provide access to that system to other persons required to sign the Manifest. A transporter is not required to provide their own equipment in order to access the system.
For more information…