The EPA's Statement About Signing Manifests During the COVID-19 Pandemic

EPA has been contacted by handlers of hazardous waste regarding the anticipated need for continued social distancing for regulated parties obtaining "wet" signatures on paper hazardous waste manifests. According to these handlers, they are conducting hazardous waste operations in states and localities with some of the highest rates of COVID-19 cases in the country. Thus, they believe continued social distancing is necessary to protect truck drivers and facility personnel and strongly urge EPA to continue allowance of the COVID-19 signature substitute policy for paper hazardous waste manifests. Therefore, EPA has determined that the approach set forth in the Temporary COVID-19 Manifest Signature Policy, as modified in this statement on manifest signatures, should continue to be available. This statement on manifest signatures is in effect until November 30, 2020, which is also the expiration date of the emergency Information Collection Request for this statement. If, however, EPA intends to terminate this statement prior to that date, the agency will post a notification at www.epa.gov/e-manifest at least seven days prior to terminating this temporary statement.

This temporary statement contains three changes from the Temporary COVID-19 Manifest Signature Policy: (1) shortening the phrase transporters or designated facilities should write in Box 15, for generator signature, to address space limitations on the manifest form; (2) changing the reference to the EPA policies about signatures on manifests during the COVID-19 public health emergency in the generator's signature substitute; and (3) removing language referencing the Temporary COVID-19 Enforcement Policy regarding how generators and transporters should maintain documentation.

On a case-by-case basis, EPA will exercise its enforcement discretion for noncompliance with the signature requirement on paper hazardous waste manifests for the period covered by this statement and resulting from social distancing efforts due to the COVID-19 public health emergency, as provided in this statement. As part of EPA's case-by-case evaluation, EPA will consider the waste handler practices described below to be appropriate behavior in response to the inability to obtain a signature on a paper hazardous waste manifest. Generators and transporters should maintain appropriate documentation demonstrating behavior consistent with this statement.

[View the full statement on the EPA website]




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