EPA released a temporary statement extending an approach with respect to signatures on paper hazardous waste manifests under the Resource Conservation and Recovery Act (RCRA) resulting from the COVID-19 public health emergency. Read the statement. If obtaining a generator signature on a paper manifest is not reasonably practicable, entities can use a fully electronic manifest. If a fully electronic manifest is not available, then the following steps should be taken: transporters should make certain notations on the hazardous waste manifest form; generators should provide a signature substitute via cell phone text message, email, or hard copy letter mailed to the transporter and designated facility; and all entities should maintain this documentation for three years from the last shipment needing a signature substitute.
This statement was in effect until November 30, 2020. EPA decided not to extend this temporary statement based on the e-Manifest system registering less than two dozen incidents of regulated industry using the policy since July 2020. Additionally, EPA consulted with hazardous waste treatment, storage and disposal companies who confirmed that companies are relying instead on other mitigation strategies to reduce risks from COVID-19.