Abundance of paper transcriptions leads to rampant errors in EPA’s e-Manifest, watchdog says

Less than half a percent of the Environmental Protection Agency’s hazardous waste shipping forms are natively electronic, leading to widespread inaccuracies generated from paper transcriptions, the Office of the Inspector General found last week. 

The forms, called manifests, are mostly handwritten and transcribing them into the e-Manifest system causes rampant data errors, the watchdog found in a review spanning Nov. 2025 through this June. 

“Data quality issues will likely persist until the full adoption of electronic manifests,” the report said. “If all handlers enter data directly into an electronic manifest, then there is no need for data to be manually transcribed, eliminating any associated data entry errors and illegibility issues.”

From 2019 through 2024, 99.6% of submissions were “data and image” submissions, which require treatment, storage and disposal facilities to manually enter data, the report said. 

There were also problems with inaccurate shipping volumes, the report said. The 100 largest volume errors caused the system to “reflect more than 1,600 times the amount of hazardous waste that was actually shipped,” misreporting millions of tons of waste, it said.

The OIG also found about 40% of the generator ID numbers and about half of the treatment, storage, and disposal facility ID numbers were invalid from 2022-2024. 

Since its launch in 2018, the e-Manifest system has managed more than 14 million manifests as of March, the report said. At launch, the EPA estimated that the widespread adoption would save $90 million in time and resources for state and industry users.

“Without the use of electronic manifests for all hazardous waste shipments, the e-Manifest system will not realize its anticipated cost savings and accuracy benefits,” the report said.

The EPA has made efforts to address these errors, the report said, providing regulators with ways to report them and responding to the OIG’s observations throughout the review.

The agency agreed with both of the OIG’s recommendations, which were to establish the maximum volume of each hazardous waste container type and implement verification checks to identify when maximum shipping volumes are likely exceeded. It has already completed corrective actions for the first and provided a plan for the other.

The EPA proposed a rule to sunset paper manifests in March. Several states responded, expressing support for more transparency and reduced administrative burden, but some were concerned about data accuracy, training, and the 24-month phase-out timeline to electronic-only.

“I’m hesitant at this time to trust only having access to electronic copies unless receiving facilities are going to be required to greatly improve their data entry standards,” the Maine Department of Environmental Protection said in a proposed rule comment. “It takes hours of our time to fix these issues with no penalty to the receiving facility and frankly we dont have time to do this on their behalf. Correction requests are being ignored for months and the same errors are being made over and over even if addressed by us previously. If paper copies are no longer used, we need receiving facilities to be held accountable for their errors.”