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The Arkansas Department of Energy & Environment – Division of Environmental Quality (“DEQ”) is circulating a Resource Conservation and Recovery Act (“RCRA”) Hazardous Waste Generator Reminder which references a March 14th U.S. Environmental Protection Agency (“EPA”) compliance advisory titled:
Data Quality Issues with Hazardous Waste Manifests Submitted to EPA’s e-Manifest System (“Advisory”)
DEQ Hazardous Waste Compliance Branch Manager, Penny J. Wilson, CPM, states that EPA has issued the compliance Advisory:
. . . to assist hazardous waste handlers in reducing data quality issues in the e-Manifest system and to support their compliance with the law. . .
Congress enacted the Hazardous Waste Electronic Manifest Establishment Act in 2012. The legislation required that EPA establish a national electronic manifest system for RCRA hazardous waste. Therefore, EPA established the national system for tracking hazardous waste shipments electronically, It is known as e-Manifest and the goal has been to modernize the United States cradle-to-grave hazardous waste tracking process.
A link to a presentation addressing the e-Manifest system that Penny Wilson undertook at the Arkansas Environmental Federal Convention in 2018 can be found here.
The March 14th EPA Advisory identified the data quality issues as:
- Inaccurate or missing ID numbers
- Manifest tracking number mismatch and invalid paper manifest usage
- Errors associated with the digitization of paper manifests
The Advisory provides suggestions for how each of these issues can be addressed.
The DEQ reminder and Advisory can be found here.
