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On February 18, 2015, the U.S. Environmental Protection Agency (EPA) released a Federal Register notice seeking nominations of candidates to be considered for a three-year appointment to the Hazardous Waste Electronic Manifest System Advisory Board (the Board). 80 Fed. Reg. 8643.
Pursuant to the Hazardous Waste Electronic Manifest Establishment Act (e-Manifest Act), EPA is establishing the nine member Board “to provide practical and independent advice, consultation, and recommendations to the EPA Administrator on the activities, functions, policies and regulations associated with the Hazardous Waste Electronic Manifest (e-Manifest) System.” The e-Manifest Act was signed into law on October 5, 2012, and requires EPA to establish a national electronic Information Technology manifest system. This system is to enable users of the uniform hazardous waste manifest to have the option to track their hazardous waste shipments electronically, in lieu of the paper manifest, from the point of generation, during transportation, and to the point of receipt by an off-site facility that is permitted to treat, store, recycle, or dispose of the hazardous waste.
The e-Manifest Act directs EPA to establish the Board by October 5, 2015. The Board is to help EPA assess the effectiveness of the electronic manifest system and make recommendations for improving the system and to establish an appropriate user fee. The e-Manifest Act requires that the Board be comprised of nine members. The EPA Administrator (or a designee) will serve as Chairperson of the Board. The remaining eight members will be individuals appointed by the EPA Administrator. Two of these must have expertise in information technology. At least three of the members must have experience in using, or represent users of, the manifest system to track the transportation of hazardous waste under federal and state manifest programs. And at least three of the members must be state representatives responsible for processing those manifests. Board members will receive compensation for travel and a nominal daily compensation (if appropriate) while attending meetings. Additionally, they will be designated as Special Government Employees (SGEs). EPA is accepting nominations until March 20, 2015.
Paper manifests have been in use since the inception of the RCRA hazardous waste regulatory program. Electronic manifests will augment or replace the paper forms and that result in substantial costs and other inefficiencies. Congress intended that EPA develop a system that, among other things, meets the needs of the user community and decreases the administrative burden associated with the current paper-based manifest system on the user community. EPA anticipates that electronic manifests will reduce the paperwork burden by reporting facilities by 300,000 to 700,000 hours annually, and will save approximately $75 million dollars.