The U.S. EPA's Office of the Inspector General identified thousands of errors in three years of data from the E-Manifest system, which preserves electronic records of the movement of hazardous waste shipments.
The office claimed an incomplete transition to a fully electronic system has left the door open for transcription errors, in turn undermining confidence in a system meant to provide accessible, public tracking of hazardous waste.
The report comes as EPA weighs comments on a proposal to require hazardous waste generators and transporters to fully commit to an electronic system, as opposed to the paper manifests still used for about 99.6% of shipments in 2024. That proposal has proven controversial with the hazardous waste management sector, which claims the EPA does not have statutory grounds for the requirement and argues it would be unnecessarily cumbersome.
At the same time, the OIG determined that a complete transition to an electronic system would prevent many of the errors it identified, and it would ensure the kinds of cost savings EPA had initially projected when it set out to create the E-Manifest system.
“More than 12 years after stating its goal to maximize the full benefits and efficiencies of electronic manifests as quickly as possible, the agency has not attained that goal,” the OIG concluded. “We encourage the EPA to continue its efforts to fully adopt electronic manifests.”
Procedural shifts
The transportation of hazardous waste is governed by the federal Resource Conservation and Recovery Act. RCRA requires a cradle-to-grave tracking framework that has been facilitated through paper forms for decades.
But in 2012, then-President Barack Obama signed the Hazardous Waste Electronic Manifest Establishment Act, which directed the EPA to create a unified national tracking platform. The law aimed to improve efficiency, data quality and regulatory oversight of the hazardous materials shipped between facilities.
The EPA has asserted that fully implementing an E-Manifest system would save regulators and the industry at large about $50 million. But the Environmental Technology Council, an industry group representing companies that handle hazardous waste like WM, Reworld, Clean Harbors, Republic Services and Triumvirate Environmental, argues costs could far exceed the agency’s projections.
The group cautioned that fully implementing the system is “complex, expensive, and must be done carefully.” ETC also noted that hazardous waste companies had already made “substantial investments in their operations and internal software systems” to help the EPA implement the E-Manifest system, with upgrade costs ranging from $1 million to $3.85 million for small to large operators.
The ETC contends that prior laws and rulemakings do not require EPA to create a “mandatory, real-time, fully paperless system or to prohibit submission of scanned paper documents.” Doing so, the group claims, would be difficult for small generators of hazardous waste, transporters and obligated parties with limited connectivity.
Earthjustice and California Communities Against Toxics supported the transition to an electronic reporting system, with some caveats. In joint comments, the groups said EPA should allow the public to review submitted data in real time, rather than the current 90-day gap. They also urged the EPA to require users of the system to fix errors promptly, rather than allow a 30-day window for corrections. Both time periods are a legacy of a paper-based system that are no longer needed, the groups argued.
But they did encourage EPA to allow for backup paper copies. They also asked EPA to include a requirement for transporters of hazardous waste to hold onto backup copies of the shipments' manifest, which they said would provide critical information to emergency responders in the event of an incident. The groups cautioned that a transition, while desirable for transparency, will be tricky.
“Given that the vast majority of regulated entities have refused and never used the E-manifest system, EPA cannot assume this transition will be seamless. Indeed, ignoring problems with implementation will foster noncompliance and jeopardize human health and the environment,” the groups wrote.
“EPA must identify and resolve any challenges to use of the E-manifest system before the sunset date, maintain persistent functionality and accessibility with full use of the E-manifest system, and effectively enforce violations of requirements under the E-manifest system,” they added.
Errors in reporting system
The OIG conducted its analysis of the E-Manifest system between November 2025 and June 2026, analyzing hazardous waste shipment data from 2022, 2023 and 2024, per its report.
Inspectors found that that “the system contains many data errors of varying significance,” mostly due to the inaccurate transcription of data from paper-based manifests. It determined that “data quality issues will likely persist until the full adoption of electronic manifests.”
Often, the generator ID errors were attributed to generators of very small quantities of hazardous material. That means that while 40% of generator IDs seen in E-Manifests were invalid, just 1% of the total tons covered by E-Manifests had invalid generator IDs. Similarly, about half the treatment, storage and disposal facility IDs inspectors found in the E-Manifest system were invalid, but less than 1% of the total tons covered by the E-Manifest system had invalid TSDF IDs.
Inspectors noted the most important errors were in overstatements of the volume of hazardous waste in an E-Manifest. Inspectors found this was often due to people reporting an incorrect unit of measurement. In one example, an E-Manifest incorrectly reported the amount of waste by a factor of 2,000 because it erroneously used tons as the unit of measurement instead of pounds.
The EPA has begun to take steps to address the concerns with the E-Manifest system raised by the OIG and move closer to the full-scale adoption envisioned by the Hazardous Waste Electronic Manifest Establishment Act.
The online E-Manifest system now flags when a user attempts to input a volume of waste that exceeds a shipping container's maximum capacity, which the OIG expects will prevent some of the transcription errors it previously identified. The EPA has also committed to implementing verification checks within the E-Manifest system, a process that is ongoing.
Meanwhile, the comment period for the Paper Manifest Sunset Rule closed on May 4. EPA is currently reviewing the comments, and its agenda indicates a final rule could come in January.
