Hazardous waste handlers will need additional ways to sign off on tracking documents if the EPA wants more companies to use its electronic manifest system, the agency’s advisory board said Thursday.
The Environmental Protection Agency’s hazardous waste electronic manifest advisory board is nearing the end of a three-day meeting to determine how streamlining electronic signatures could make it easier for companies to switch from paper to electronic tracking documents.
The agency’s e-Manifest program, a hazardous waste tracking system it launched in 2018, has had far fewer users than the EPA anticipated. The EPA says e-Manifest will modernize hazardous waste tracking and save time and resources for industry and states. It also provides a central location for states and federal agencies to get information for enforcement efforts.
The advisory board previously recommended the agency reevaluate its electronic signature requirements, which are effectively more stringent compared to paper documents. The board emphasized at its teleconference meeting Thursday that flexibility within the EPA system is essential.
Emphasis on E-Signatures
The coronavirus has also changed signature practices, said Jill Macioch, board member and environmental team lead at Xcel Energy Inc. At her company, employees have been directed not to sign digital devices in order to reduce their potential exposure to Covid-19.
“Hopefully this is a one-time situation, but will there be unique circumstances in the future to prevent people from signing?” she said.
The regulated community needs as many signature options as possible in order to find the best fit for many different kinds of companies, said Joshua Burman, an advisory board member and specialist at the Minnesota Pollution Control Agency. The options, as presented by the EPA, include using a digital signature pad like a tablet or smartphone, or assigning each user a digital identification code and key.
Some companies aren’t adopting the system because they already have their own electronic systems, while others are opting to stick to paper because it works for their needs.
The fully electronic approach to hazardous waste manifests “is an all-or-nothing approach,” said Tom Baker, an advisory board member and vice president of environment and transportation at Veolia North America LLC.
Too High a Hurdle?
Authentication requirements could be too high a hurdle for some companies to opt into the system, the board members said. If some hazardous waste handlers adopt the EPA’s electronic manifest system and others don’t, the system is much less effective, Burman said. States are able to educate regulated companies about the system, but can’t require them to use it.
Creating a validated electronic signature for the EPA system involves multiple steps, including requesting access from a site manager, completing an agreement electronically or by mail, and setting up an account and personal challenge questions. Depending on the jurisdiction, the EPA may be the authority that receives and verifies the signed agreement.
Once a user has a validated electronic signature, he or she must answer a personal challenge question each time a document needs to be signed or corrected.
The EPA will review the board’s comments and release a formal response at a later date, said Fred Jenkins, the board’s designated federal officer.
Any new signing methods the EPA wants to implement after the advisory board meeting could complement the current method and not necessarily replace it, Amanda Kohler, chief of the EPA Office of Land and Emergency Management’s permitting branch, said at the board meeting on Tuesday.
As of the end of February, electronic manifests and a hybrid of paper and electronic made up less than 1% of the 3 million manifests the agency has received so far, according to the EPA. The agency’s goal is to have at least 75% of manifests be electronic or hybrids by June 30, 2022.
The board’s advisers are state representatives, information technology professionals and manifest system users.
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