Non-Substantive Change Request Justification

Request for a Non-Substantive Change

to an Existing Approved Information Collection

(EPA ICR No. 0801.24; OMB Control No. 2050-0039)

I. Introduction

Why is EPA Requesting a Non-Substantive Change?

EPA is requesting a non-substantive change in order to implement the same typographical correction to instructions printed on the paper versions of the following approved EPA forms:

• EPA Form 8700-22 (Uniform Hazardous Waste Manifest).

• EPA Form 8700-22A (Uniform Hazardous Waste Manifest – Continuation Sheet).

EPA is not otherwise modifying the information collection requirements or agency paperwork burden estimates.

II. Description of Non-Substantive Changes

What Information Collection Request (ICR) is EPA changing?

ICR Title:	Requirements for Generators, Transporters, and Waste Management Facilities under the RCRA Hazardous Waste Manifest System Final Fee Rule (Renewal)
ICR Numbers:	EPA ICR No. 0801.23; OMB Control No. 2050-0039

What is the current status of this ICR?

This ICR is currently approved through January 29, 2021.

What are the changes that EPA is making to this collection of information?

The instructions printed on the Paper Manifest versions of EPA Forms 8700-22 and 8700-22A include a note addressing the e-Manifest Act and EPA’s e-Manifest system, which launched in 2018. The note in these instructions incorrectly includes the term “hazardous” when referring to any facility that receives a paper manifest accompanying a federally regulated waste. The e-Manifest Act, however, extends to any shipment of hazardous waste or other material that is required to use a manifest to comply with any federal or state requirement. This includes hazardous wastes under the Resource Conservation and Recovery Act as well as any other material that must be manifested according to state or federal law, such as polychlorinated biphenyl (PCB) waste under the Toxic Substances Control Act regulations. Removing the word “hazardous” avoids confusion and reflects better the statutory requirements under the e-Manifest Act.

EPA is correcting identical notes on copy 3 (Designated Facility Copy) of the Paper Manifest versions of EPA Forms 8700-22 and 8700-22A as follows:

Note: The e-Manifest Act mandates several changes to the federal manifest program. Beginning on June 30, 2018:

• This continuation sheet (Revision 12-17) must be used and all previous editions are prohibited.

• Any facility (e.g., a RCRA-permitted facility, Subtitle D facility) that receives a manifest and any continuation sheets accompanying a state-only regulated waste must comply with 40 CFR 264.71 or 265.71 (use of the manifest) and 40 CFR 264.72 or 265.72 (manifest discrepancies).

• Any facility that receives a paper manifest accompanying a federally regulated hazardous waste or state-only regulated waste must submit the top copy (Page 1) of the manifest and any continuation sheets to the U.S. EPA’s e-Manifest system within 30 days. The copies must be submitted in an acceptable format. Submissions must be made at the mailing address or electronic mail/submission address specified at the e-Manifest program website’s directory of services (see www.epa.gov/e-manifest).

• The facility will be assessed a fee for each manifest copy submitted.

• Go to www.epa.gov/e-manifest for the directory of services and additional information.

No corrections to EPA’s electronic manifest and related user guide are needed.

Will this change impact the annual ICR burden estimates?

No. The current ICR annual burden will not change.

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