Effective January 22, 2025, new regulatory requirements under the Final Rule: Integrating e-Manifest with Exports and Other Manifest-Related Reports, PCB Manifest Amendments, and Technical Corrections (Third Rule) will take effect. These changes will significantly impact Large Quantity Generators (LQGs) and Small Quantity Generators (SQGs), requiring updates to their RCRAInfo system accounts and permissions to maintain compliance.
If someone at your facility already holds Site Manager or e-Manifest Certifier permissions, no additional actions are necessary. However, all facilities should verify their readiness for these changes.
Key Compliance Deadlines
- January 22, 2025:
- Receiving facilities will no longer mail completed manifests to generators.
- LQGs and SQGs must retrieve final manifests via the e-Manifest system.
- Corrections to manifest data requested by regulators must be submitted electronically.
- December 1, 2025:
- Generators must secure Site Manager or e-Manifest Certifier permissions to perform electronic corrections.
- Exception report submissions will shift to an electronic-only process via the e-Manifest system.
Actions to Take Now
- Update Site Permissions
Ensure your RCRAInfo system permissions are upgraded to Site Manager or e-Manifest Certifier:- Log into RCRAInfo with your registered account.
- Click your profile name in the top-right corner and select “My Site Permissions.”
- Choose the appropriate checkboxes for permissions and click “Modify Permissions for Selected Sites.”
- Submit your request to your State or the RCRAInfo Site Manager.
- Delegate Permissions If Necessary
Not the right person to update permissions? Share user registration instructions with the appropriate team member. - Submit Updates for Status Changes
If your site’s generator status has changed (e.g., becoming a Very Small Quantity Generator or no longer regulated), contact your state to file an updated Site Identification Form (Form 8700-12).
Benefits of Staying Compliant
These updates are designed to streamline waste tracking, improve transparency, and enhance compliance with EPA regulations. Early preparation ensures your facility avoids disruptions and penalties.
For questions or assistance with registering in the RCRAInfo system, contact Compliance Management International (CMI) at CompliancePlace.com.
FAQs on the New LQG and SQG Requirements
- What is the e-Manifest system?
- The e-Manifest system is an EPA-developed electronic platform for tracking hazardous waste manifests.
- Who needs Site Manager or e-Manifest Certifier permissions?
- Any facility required to retrieve manifests, submit corrections, or file exception reports electronically.
- What happens if permissions are not updated?
- Facilities without appropriate permissions may face compliance issues, delays, or penalties.
Stay ahead of these changes—ensure your facility is ready for January 2025! Contact Us to learn more on how we can help your organization prioritize employee well-being and productivity.
