The Wise Report
Henry M. Wise, P.G.
June 9, 2018
As you know, the Texas Board of Professional Geoscientists (TBPG) is currently undergoing their periodic Sunset Commission Review. In preparation for their report, a PG License Work Group that consists of representatives of the Houston Geological Society, AIPG, AEG, AAPG, and Texas Association of Professional Geoscientists has been formed to help coordinate any defense we may need to provide to the TBPG. I’ll be reporting on any activities that come up.
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The EPA's changes to the Uniform Hazardous Waste System are scheduled to occur on June 30, 2018. That's when the paper manifest will go from a 6-ply to a 5-ply form. The new format does not affect the data you fill out on the form, but does affect the form's final destinations. In the past, copies of the manifest stayed with the generator, the transporter(s), and the disposal facility, and copies were sent to the generator's state and to the receiving state. Now, instead of going to the states, one copy will be sent to federal EPA.
EPA plans to enter the information from the manifests into a central, publicly accessible database.
You will also have the option of using EPA's new electronic hazardous waste manifest system, called e-Manifest. While you will be able to access electronic manifests on EPA's website, be sure to work with your treatment, storage, and disposal facility to ensure a smooth transition. EPA will begin charging these facilities for every manifest submitted to the federal database; in turn, the facilities will pass on the costs to you.
TSDF Guidance from EPA:
"EPA will accept Page 1 copies of the obsolete 6-copy forms for processing after June 30, 2018, but we strongly recommend that users transition to the 5-copy forms as quickly as possible. If a user wishes to continue to use the obsolete 6-copy forms, they should undertake measures to minimize confusion in their use, such as applying a pre-printed adhesive label to the top copy with the accurate copy distribution language ('designated facility to EPA's e-Manifest system'). Facilities should train their manifest personnel to inspect manifests carefully to ensure they are routed properly during the time any of the obsolete manifests remain in use."
Henry M. Wise, P.G.
The Wise Report
6/9/2018