The “hybrid” or mixed paper / electronic manifest is a specific manifest approach that EPA adopted to assist generators who are not able to fully participate in electronic manifesting at the time of system launch (June 30, 2018). The hybrid manifest allows transporters to initiate an electronic manifest in e-Manifest and use this manifest with their non-participating generator customers. The initial transporter may print a copy of the electronic manifest for the generator, and the generator may sign the paper copy, obtain the initial transporter’s ink signature on this paper copy, and then retain this paper copy on-site as the generator’s initial manifest copy as is done under traditional manifest requirements. Thereafter, the initial transporter and subsequent waste handlers will complete the remainder of the tracking of the shipment electronically in e-Manifest with electronic signatures and electronic transmissions to the system. Hybrid manifests are charged the same fee as a fully electronic manifest.
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