EPA’s e-Manifest Advisory Board Meeting: What EHS Leaders Need to Know

On September 23, 2025, the EPA held its 9th e-Manifest Advisory Board Meeting. The central theme: how to finally move hazardous waste tracking from paper manifests to a fully electronic system. For environmental, health, and safety (EHS) leaders, the session offered both encouraging signals and a few surprising developments. Both of which could reshape compliance strategies in the years ahead.

The Current State of e-Manifest

Since the system launched in 2018, it has processed nearly 13 million manifests. But here’s the striking detail: more than 99% are still submitted on paper. Even the EPA acknowledged that adoption of electronic submissions has been slow — including in its own cleanup programs.

The ongoing reliance on paper creates persistent problems: poor data quality, slower reporting, and extra administrative burden. It also runs counter to EPA’s long-term vision of a digital system that improves oversight and makes compliance more efficient.

DOT’s Role: Aligned in Spirit, But Not in Practice

Representatives from the U.S. Department of Transportation (DOT) emphasized that they support electronic systems for hazardous materials. Railroads, for instance, already use them under special permits.

But when it comes to hazardous waste, DOT made clear that its regulatory priorities don’t always match EPA’s. That leaves industry with a familiar challenge: navigating two agencies moving in parallel but not always in sync.

QR Codes: A Practical Innovation

One promising highlight was the rise of QR codes. EPA sees them as a scalable solution for electronic signatures and shipment validation. Imagine a transporter scanning a QR code in the field to instantly confirm shipment details — no paper copies required.

Industry feedback has been positive, and EPA appears ready to expand QR code pilots as part of its broader push toward digital workflows.

The Biggest Surprise: Rethinking the Biennial Report

The late-breaking headline of the meeting was unexpected: EPA is weighing the elimination of the Biennial Report (BR). Though not originally on the agenda, the idea gained strong support from board members. That said, this is not the first time EPA has suggested this in prior eManifest board meetings, and the BR still remains.

The logic is simple. If all manifest data becomes electronic and centralized, the BR could be redundant. But the implications are complex:

• State-level impact. Without EPA’s BR, states may create their own reporting rules, leading to patchwork requirements.
• Data gaps. Manifests don’t capture all the details of the BR, which could complicate TRI reporting when EPA just assumes an entire shipment weight is the entirety of a reportable chemical (e.g. Chromium compounds).
• Industry readiness. Organizations will need systems that track all waste streams — not just RCRA-regulated ones.

For EHS leaders, this reinforces an important truth: compliance isn’t just about checking boxes. Comprehensive, accurate waste data management will be essential.

What’s Next on EPA’s Agenda

The Advisory Board will continue shaping recommendations around:

• A timeline to sunset paper manifests.
• Expansion of electronic signature options, including QR code pilots.
• Exploring DOT’s special permit pathways for hazardous waste transport.
• More user support through workshops, training, and possibly a national conference.

Why This Matters for EHS Leaders

Several takeaways stand out:

• Early adopters will gain an advantage. EPA pilots show that once policy changes are mandated, adoption moves fast. Getting ahead now reduces future disruptions.
• The Biennial Report could disappear. If that happens, reporting will likely shift toward state requirements, which may be more fragmented.
• Digital workflows are no longer theoretical. QR codes, electronic signatures, and real-time data validation are the direction of travel.
• Dual compliance is here to stay. DOT and EPA won’t always align, so organizations should prepare for overlapping requirements.

What to Watch

VSQG Site Managers. 

The board talked about requiring every site with an EPA ID number — even Very Small Quantity Generators (VSQGs) — to have a named site manager. Right now, this is only suggested. Making it a rule would help states deal with staff turnover but would also add new responsibilities for VSQGs.

Manifest Corrections. 

EPA also highlighted the need for more accurate manifests. Generators can already make updates before shipment on electronic and hybrid manifests, and transporters may help if needed. Once a generator signs — on paper or electronically — the standard correction process applies through e-Manifest. What’s important is EPA’s signal: it wants fewer errors in the system. As paper records shift into digital, generators will need to double-check their data so they don’t have to rely on EPA to catch mistakes later.

Encamp’s Take

If EPA ultimately retires the Biennial Report, organizations will need a more holistic approach to managing waste data. That’s where Encamp helps.

Encamp Waste is designed to track all waste streams — not just RCRA-regulated ones — giving EHS teams confidence that they’re capturing the full picture. By modernizing compliance systems today, leaders can be ready for whatever comes next.