(Brookfield, WI – July 3, 2018) PharmEcology Services, WM Sustainability Services
On July 1, 2018 EPA launched its Hazardous Waste Electronic Manifest System, known as e-Manifest, for the tracking of hazardous waste, including hazardous waste pharmaceuticals, from the generator through to final disposal. EPA has provided several options for managing the new five-part manifest, which replaces the former six-part manifest. EPA has established the e-Manifest system according to the Hazardous Waste Electronic Manifest Establishment Act, enacted into law on October 5, 2012. The “e-Manifest Act” authorizes the EPA to implement a national electronic manifest system and required that the costs of developing and operating the new e-Manifest system be recovered from user fees charged to those who use hazardous waste manifests to track off-site shipments of their wastes. Generators should check with their hazardous waste vendor for their e-Manifest fee schedule.
EPA is requiring additional security requirements around certain P- and U- listed wastes, including nitroglycerin, P081, chloroform, U044, ethylene oxide, U115, ethyl ether, U117, and formaldehyde, U122, which are considered to be “Chemicals of Interest” (COI) by the Dept. of Homeland Security. At this time, manifests with these waste codes should be sent to EPA via hard copy mail only. Generators should confirm with their hazardous waste vendor that their hard copy manifests with these waste codes will be mailed to EPA from the receiving facilities (TSDFs). The complete list can be found HERE.
It is important to remember that weak nitroglycerin in finished dosage forms has been excluded from RCRA regulation as it does not exhibit the characteristic of reactivity (40 CFR 261.3(g)). Several states have either not adopted this exclusion or list medicinal nitroglycerin under their state hazardous waste designations. If your state requires nitroglycerin to be listed as P081 on the hazardous waste manifest, hard copies should be mailed to EPA and not submitted electronically.
Additional information regarding the e-Manifest system, including a webinar and FAQs, can be found at https://www.epa.gov/e-manifest.