﻿Please Note: This document is a guide to the discussions between the EPA and their stakeholders during the e-Manifest Virtual Public Meeting dated October 27, 2021

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Stephen Donnelly: Alright, good afternoon and welcome everybody to the first of our electronic.

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Stephen Donnelly: meetings on increasing electronic adoption attract manifests Thank you very much, please note that the recording and transcription has now started, and we will post these in the docket as soon as we are able to.

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Stephen Donnelly: And let's get things kicked off with a few opening remarks from the division director of the.

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Stephen Donnelly: program information and implementation division sorry implementation information division that's so nice, so thank you very much so.

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Sonya Sasseville: All right, good afternoon, everyone and Steve I'm not surprised that you would put information first being doing what you do, but anyways good afternoon, everybody, welcome to the manifest virtual public meeting.

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Sonya Sasseville: on increasing adoption of electronic manifests, thank you for joining us today.

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Sonya Sasseville: If you've been following our program for a while, you know that one of our long standing and top priority goals of the manifest program is to move from paper to electronic manifesting.

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Sonya Sasseville: widespread adoption of electronic manifests is how we will truly unleash the benefits of a manifest including.

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Sonya Sasseville: maximizing cost savings and burden reduction, improving the quality of manifest data integrating manifests with the bi-Annual Report requirements and enhancing monitoring of hazardous waste shipments nationwide so we're at an exciting time for a manifest since launching.

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Sonya Sasseville: In 18 we work together to lay the foundation of our program EPA spend time by way of several manifest advisory board meetings and other feedback than us learning the needs and challenges of our stakeholders with respect to a lot electronic manifesting and we're trying to.

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Sonya Sasseville: address them so in 2020 was concurrence from the E manifest advisory board we updated our policy with respect to electronic signatures for.

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Sonya Sasseville: generators transporters and initial signatures by receiving facilities and we implemented the new quick sign feature quick sign was a dramatic improvement to our electronic manifesting process.

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Sonya Sasseville: However, we know that this isn't enough electronic manifests still represent just about a half a percent of the total manifest volume.

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Sonya Sasseville: So definitely that's not where we want to be in 2021, we committed to the manifest Advisory Board to explore other potential solutions to increase electronic manifest adoption among users.

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Sonya Sasseville: Which brings us to today's public meeting our objective today is to get early input from you that we can use in defining potential options for future consideration by the manifest Advisory Board.

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Sonya Sasseville: What you hear today by no means represents formal proposals or concrete plans by the Agency, we are at the idea stage and your input will be very valuable to shaping where we go next.

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Sonya Sasseville: As we go through this process, I encourage you to keep an open mind and embrace changes that may relate to your own current practices and systems in moving toward electronic manifest.

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Sonya Sasseville: We have always taken pride in this program in the fact that your manifest successes and shared success among our users among state and EPA regional partners and, among others, that use and derive value from the data.

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Sonya Sasseville: So, I encourage us all to continue working together to make this next bleep possible with that.

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Sonya Sasseville: I know that the manifest team is ready to begin presenting and eager to listen to learn from our stakeholders, I look forward to seeing the outcome of our time together. Thank you again and I'll turn it back over to Steve.

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Stephen Donnelly: All right, thank you, Sonya we have an action-packed agenda and if you.

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Stephen Donnelly: want to know what's going on, so yeah so for the first part of the meeting we're going to lay out our objectives as a background and we're and we're going to go through our current.

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Stephen Donnelly: manifest workflow we want to get everybody sort of a ground sort of ground truth, a lot of the basic workings of the current system before we can move on, we have a break at 2:50pm over.

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Stephen Donnelly: Where we're going to collect our thoughts and then we'll get into a policy discussion and talk about some EPA signature policy, as well as proposed options and go to the Statute regulations, and then we will adjourn and do remember that this is a.

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Stephen Donnelly: This is, first of a public meeting of our electronic  adoption and public meetings we're going to do more.

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Stephen Donnelly: we're going to have another session next week and then, if there is a desire and there's a need to be able to do more things all right, well, thank you very much I'm going to pass this along to David Graham.

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David Graham: All right, thank you Steve before we get started, I know everyone's excited.

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David Graham: and eager to start talking about electronic manifests a few housekeeping items, so please keep yourself muted throughout meeting.

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David Graham: In fact, since we're using zoom it's going to be.

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David Graham: very difficult for you to unmute yourself unless we ask you to. If you'd like to comment during the discussion periods, please use the raise your hand button and then we'll ask you to unmute yourself.

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David Graham: You can put questions in the Q and Abox, the entire time that we're presenting, and we'll try to address them and timely manner and those that we can't get to today will try to get or those we can get to immediately will try to get to at the end of the session.

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David Graham: Also note that the proposed agenda times that Steve just outlined are approximate we may end a little early if one of the Q and A sessions doesn't last long comments you know presentations don't take as long So those are approximate time, so we encourage you to stay tuned.

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David Graham: And also, please note that this meeting is being recorded, and the recording as well as the transcript will be posted in the public docket which will share a link with you here in a moment.

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David Graham: Please note you can also submit any written comments to the d docket until December 30 so it's open for a limited time.

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David Graham: With that I'm going to pass it back over to Steve.

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Stephen Donnelly: Oh, right Thank you Thank you again so let's go through our meeting objectives and background, so this is, I hope we all know why we're here, but in case we go let's go let's go to the next slide and see where we are.

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Stephen Donnelly: So, the manifest.

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Stephen Donnelly: To achieve the at the objectives of the hazardous waste electronic manifest establishment and or as we like to call the manifest act includes decreasing birth.

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Stephen Donnelly: And the only way we can decrease burden and achieve integration with by not reporting and really move this program forward is to.

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Stephen Donnelly: have wide adoption of electronic so we get somewhere in the neighborhood of 2 million manifest per year and it currently represents less than 1%, so we are, we are in, we are in.

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Stephen Donnelly: We are looking forward to getting some more manifester.

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Stephen Donnelly: And we understand that we're not getting a lot, and this is far, far short of the expectations -- industry expectations and state expectations of where we should be after three years of operation, when it comes to adopting electronic methods.

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Stephen Donnelly: So, we can go to the next slide, so This brings us to these meetings, so the purpose here is to get your individual feedback and ideas and ways to increase adoption of electronic manifests.

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Stephen Donnelly: We are going to use this information to develop further options for the Advisory Board to consider in a public meeting we're planning for the county or 2022.

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Stephen Donnelly: And in addition to that sort of thinking about the future, we want to think about where we are in the present, so another objective of this meeting in a very good one, is to.

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Stephen Donnelly: get a sort of inform and educate our stakeholders, particularly on the industry side, about the use of our current electronic workflow particularly how it can be used by a service.

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Stephen Donnelly: By building on what we see a lot of for data plus image, so we have an in place.

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Stephen Donnelly: Where methodology of receiving data from our industry systems that is widely roughly 80% to 85% of the manifest data coming in, is through our services.

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Stephen Donnelly: And we can also do the electronic workflow much of it through our services, so we want to be able to increase understanding and use of our current workflow so that will help us in two weeks we'll be able to.

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Stephen Donnelly: Potentially see an increase in electronic debt adoption on our as his system, and if there are further options for the Advisory Board to consider and we have a robust back and forth conversation.

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Stephen Donnelly: In the series of meetings and through public commenting we will be able to have a better educated.

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Stephen Donnelly: stakeholder Community proposing options, seeing as they now know how exactly how the current system works.

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Stephen Donnelly: So, we're going to get everybody on this on the same page.

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Stephen Donnelly: All right, and then as well we're going to be  hitting this a lot, but all the materials for these meetings are going to be going on to our public docket.

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Stephen Donnelly: And we will be accepting written comments until December 30, 2021, so just about until the end of the year, so please, if you have a question or an idea and it doesn't get covered, or if it's sort of.

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Stephen Donnelly: not fully developed yet, and you don't feel like sharing it in the Q&A box or raising your hand, please, where are.

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Stephen Donnelly: We are imploring you to make your feelings heard in the in the public the public docker so we can consider those, and we'll have you guys considered public, so please, please, please, please go into the docket.

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David Graham: Alright, so a couple more logistical items to take care of before we really kicked this meeting off, is that this is not a federal advisory committee meeting or not a FACA meeting.

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David Graham: Right so, as such, we need to ensure that we abide by certain procedures right, and this perfect I should say generally applies to groups that EPA establishes to utilize.

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David Graham: an interest in obtaining group advice and recommendations right, so we take our factor responsibilities very seriously and,

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David Graham: at the same time, we also to we're also seeking input from individuals outside of the FACA process and entities.

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David Graham: not subject to FACA right I'm.

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David Graham: Sorry, so the takeaway here is that.

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David Graham: We are seeking individual input not collective advice today right.

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David Graham: So, if an organization sends a representative to more than one meeting that's considered to be the same individual attending, even if the organizational sends different individuals to the meeting.

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David Graham: Additionally, if an organization and sends two or more people to the same meeting, they are still providing individual input from one organization.

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David Graham: So, during today's discussion and during those Q and A sessions, we welcome discussion, but we ask that you direct your comments to EPA not towards each other.

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David Graham: In addition to directing your comments towards the EPA this meeting is solely focused on increasing the adoption of electronic manifest.

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David Graham: And as such we're going to try to steer this conversation away from their hot topics, you know we e-Manifest is.

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David Graham: Is multifaceted but today we're going to try to stay away from data quality, paper manifest concerns, waste determinations, user fees, as well as even the third rule making right so.

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David Graham: Thank you very much for your help and giving us a.

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David Graham:  focused conversation today now with that I'm going to turn it back over to Steve.

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Stephen Donnelly: Okay, thanks, David I so let's do a brief history of the manifests and electronic signature, so this is not the entire history, this goes back to well before June 2019, but this is sort of where things get interesting.

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Stephen Donnelly: As far as you know, bringing us all together so in June 2019 we had an advisory board meeting specifically requesting information to understand from our users, the barriers to using electronic methods and actions, we could take to enhance the widespread enhance adoption.

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Stephen Donnelly: We propose some items we had we had great back and forth via some great public commenters and in September 2019 after we receive the advisory board's recommendation, they asked the Agency to reconsider whether.

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Stephen Donnelly: All users need to adhere to the existing registration process and consider changing.

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Stephen Donnelly: Changing or eliminating the Cross media electronic reporting rule requirement for transactions prior to receipt as well as reevaluate.

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Stephen Donnelly: Signature requirements in general, so essentially the feeling from the Advisory Board was please take a look at the laws governing your electronic signatures and.

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Stephen Donnelly: report back to us, so we did so we can go to the next slide.

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Stephen Donnelly: All right, alright, so we followed on the board's recommendation so for those of you in who remember April 2020 This was our first electronic our first virtual.

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Stephen Donnelly: Public meeting or online public meeting, there is no in person, it was April 2020 and big thanks to the team for pulling that, all together, that was a lot of a lot of fun stuff.

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Stephen Donnelly: Behind the behind the curtain to get that going we proposed additional methods for increasing the use of electronic manifest.

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Stephen Donnelly: This included re-engineering signatures for the generator transporters to reduce the burden and barriers to electronic manifest essentially.

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Stephen Donnelly: We proposed among several items essentially removing the CROMERR requirement from non-final signatures of a manifest so this could be a this could be for your final so a generator transporter initial receipt and then chromium requirements would win for me and for the.

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Stephen Donnelly: Any final signatures are correct, and we propose that and then July we received concurrence that removing those requirements for non-final signature is the manifest was a good idea and.

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Stephen Donnelly: Also, you can we receive recommendations to continue to work to integrate a manifest with industry systems by data services by using a PS.

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Stephen Donnelly: Alright, so wow it's October 2020.

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Stephen Donnelly: Okay, so it's a year ago, so we responded to the advisory board's recommendations confirming that the chromium requirements apply only to.

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Stephen Donnelly: Final signature of the manifest or post received corrections.

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Stephen Donnelly: And they will not apply to any non-final.

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Stephen Donnelly: And we also said, we will continue to work with our stakeholders to explore solutions that will lower barriers to lower barriers of entry or industry, so they can do or electronic manifests, as we all want.

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Stephen Donnelly: And also, this is a big thing in December 2020.

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Stephen Donnelly: We deploy the new quick sign functionality, which has been used where a non-final signature can be signed by anyone who has access to a site that is not viewer, and they can just click a button that says click sign and then manifest is science.

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Stephen Donnelly: To the wild come up with that name, but we do, we have seen a slight increase electronic manifest since quick sign has been deployed.

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Stephen Donnelly: All right, in March 2021 just a few months ago.

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Stephen Donnelly: We had an advisory board meeting to.

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Stephen Donnelly: To work through our program priorities and associated user fees for the fyi 2223 fee cycle and a key priority of that.

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Stephen Donnelly: Of the work and that cycle was to is to since we're in it now is direct engagement with stakeholders to increase electronic manifest submissions one of the reasons, we're here and.

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Stephen Donnelly: We also and then in May we receive our recommendations from the Advisory Board.

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Stephen Donnelly: that the agency address lack of industry, adoption and to integrate with our hazardous waste industries private systems.

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Stephen Donnelly: With the math so you've heard this before we heard it again very strongly that they wanted that people want direct engagement to increase electronic manifest and.

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Stephen Donnelly: sort of how that will happen is with the e-manifest system and industry systems talking to each other.

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Stephen Donnelly: and June 2021 just a few months ago.

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Stephen Donnelly: And our and our responses Advisory Board, where we finalized our user fees, we also committed to holding public meetings later in 2021.

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Stephen Donnelly: To discuss potential options for improving the use of electronic manifests which is it is why, which is why we're here so.

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Stephen Donnelly: This was a as a brief history of the background of this issue, essentially be heard, for a very long time that people industry once.

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Stephen Donnelly: More integration with the e-manifest system and that will get us more electronic manifests, so now we are here.

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Stephen Donnelly: To discuss that and it's going to get a little bit technical because you know we've  gotten past the broad strokes of.

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Stephen Donnelly: Okay, we want to integrate Well, now we have we have the Y or that but now we have to do the House so it's going to get a little tactical on the policy side it's going to be a lot tactical on the it side, but ultimately, we feel this will be really productive conversation so.

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Stephen Donnelly: To take it away, I will pass the baton off to the manifest technical lead Scott Christian.

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Scott Christian: Thank you Steve.

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Scott Christian: All right, the current electronic manifest workflow.

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Scott Christian: Please next slide so this section we're going to go through the current electronic manifest workflow, with the focus on services.

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Scott Christian: Looking at the attendee list pretty much everyone has seen what the Web user interface version of our electronic manifesting has.

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Scott Christian: gone through, if not, these are recorded we've gone through them a lot of times, so we're going to delve in deeper into services.

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Scott Christian: Then we're going to take you through the API's as they relate to the full electronic workflow in the hybrid workflow to go deep into each step that you can see it and so you can repeat it, and finally be handing the

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Scott Christian: baton over to William Nicholas who developed a DEMO using the Python language.

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Scott Christian: Using those previous two scenarios that I had at the  described. David please go to the next slide. This slide sets our expectations and explanations for this section.

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Scott Christian: This section is going to be technical we're trying to show you how easy it is for your systems to talk to the manifest and we're going to do our best to explain.

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Scott Christian: What this isn't how it is, but if you're not an IT person, please stay and  pay attention take notes and be sure to share this recording with the appropriate IT staff.

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Scott Christian: We want you all to have those conversations internally as well, and if you use a third-party system, please share with your third-party system with contractors.

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Scott Christian: we're also providing you examples, step by step, so that your IT staff can recreate this DEMO in your own tools and systems.

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Scott Christian:  I'll get to that a little bit later, and please contact us with questions.   The reason I put contact us and double quotes is because we have a contact us slide at the end.

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Scott Christian: And since we're trying to get things in the docket and create this conversation that everybody on the team can see please use that contact us and, yes, as many of you are familiar, were very receptive to answering questions about.

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Scott Christian: API's recently went through a big, long.

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Scott Christian: With.

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Scott Christian: Helping a bunch of sites move from mail to image plus data and fully electronic manifesting using services and the Web APP.

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Scott Christian: we're experienced and helping folks get to that goal, we  definitely want you to ask questions, and please ask them to the contact us.

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Scott Christian: I'm going to take the process slow at the beginning part when I'm explaining each step, because when Williams takes over it shows the DEMO it's going to go pretty fast, just like your transactions do today.

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Scott Christian: So, and biggest caveat and William will.

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Scott Christian: put this caveat at the end as well we're trying to show you options, there are a lot of ways to use web services, as you will see.

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Scott Christian: find the ways that work best with your systems and another reason why we're doing this section 85% of our manifest comm system, so this is where

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Scott Christian: the bulk of the manifests are coming from.

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Scott Christian: let's leverage that next slide please.

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Scott Christian: So, I'm going to dive in and ask you to explain you what is a rest API.

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Scott Christian: And this is our system, the system infrastructure, before we even get to rest is what is an API, an API is an application programming interface it's a  how systems talk to each other.

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Scott Christian: Similar a user to a user interface in the APP, with an API one system sends a request the other one response to that request.

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Scott Christian: Rest API's are a type of API they stand for Representational State Transfer.

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Scott Christian: API and that PhD computer science speak for basically you're taking something.

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Scott Christian: And you're sending a representation of that in the state that it was in at the time.

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Scott Christian: It was requested to another application. My favorite example on explaining this is the Mona Lisa pretty much everybody on this call today has seen the Mona Lisa a representation of Mona Lisa some of them seen the real thing but everybody has seen a representation of the Mona Lisa.

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Scott Christian: At the time, that that image was taken and let's say the Louvre in their infinite wisdom decides, they want to do something to the Mona Lisa to make it last another 500 years.

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Scott Christian: and

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Scott Christian: They do their

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Scott Christian: magical stuff that they need to do, and now there's a new representation of the Mona Lisa that will last another 500 years.

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Scott Christian: we've all seen the manifest.

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Scott Christian:  representation from before, and now the new representation, we will see.

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Scott Christian: 

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Scott Christian: The hopefully that figures that that that helps another reason we use this is because think about the manifest representation of the manifest the generator sees.

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Scott Christian: Is one representation, they sign it, the transport a sees another representation of that manifest then they sign it, and finally the TSDF sees that representation of that manifest when they sign it with all the signatures on.

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Scott Christian: So, the manifest changes throughout and the API's are shooting manifests up and down accordingly.

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Scott Christian: great thing about rest is it's well understood by developers globally it's pretty much how the Internet talks chances are you're probably using ReST API's to watch this.

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Scott Christian: Presentation we're on teams, I would say, you were but I haven't checked out zoom's back-end chances are they're using rest as well.

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Scott Christian: So, it's there they're everywhere lot of people know how to use it and the more talent, to the ups and downs of systems sure how the next slide.

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Scott Christian: So, wanted to kind of reiterate the point and show an image or a couple slides reporting kind of a bigger detail user provides a username and password in the system, except for credentials and creates a login.

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Scott Christian: Industry system provides an API and key and accepts credentials and creates an API session so.

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Scott Christian: yeah it's kind of in a nutshell, how API's were, sends a request sends back a response.

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Scott Christian: For the next slide.

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Scott Christian: So now we know that they send responsible, how do they communicate well how do we know what that request is and what that responses.

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Scott Christian: In our we use JavaScript object notation there's other.

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Scott Christian: file formats out there, that people use yeah xml but json is basically it's a text file with predictable format.

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Scott Christian: And it allows in a repeatable.

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Scott Christian: Reliable wait for one system to send a request and tell the other system what they're doing, and then the other system to send a response back.

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Scott Christian: json consists of a key and a value pair, the key is what identifies what you're trying to convey, so the example I have here is printed DOT information is the key so on every manifest that has a hazardous material on it.

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Scott Christian: There is a printed DOT information key on each waste line and then there's about a pair which is going to be different for pretty much every manifest.

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Scott Christian: In this case, it's NA1993 waste diesel fuel as a Class three packing group three.

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Scott Christian: So, with that you can kind of see an example and on the next slide we have a map.

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Scott Christian: So, you look at the bottom of the map, there is our waste-lines sections nine through 13 up above, we have our.

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Scott Christian:  json, and so the json if we look at the first one says  DOT hazardous true if you look down at the image there's an x and showing that it is true.

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Scott Christian: Then we go to printed DOT information.

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Scott Christian: And we see the same thing that's printed in section nine is also what was on the previous slide to for consistency sake.

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Scott Christian: And then, if we go through the rest of the waste line will see the container number the container type on the manifest it says DM there's also an optional field for description that shows, those are metal drums give a little more.

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Scott Christian: info for the site was to gather that information same thing with quantity and unit of measurement and, finally, that has just placed us in this example, there are no State waste codes or Texas Waste codes so they don't show up that's an empty array and optional right.

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Scott Christian: So that's in there for you all, and when you download, the slides let's go to the next slide so.

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Scott Christian: To bring us all back why use our API and David kind of summed it up great on and through the slide is this idea of the same reason you just nail gun instead of a hammer.

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Scott Christian: A hammer and nail into boards and it will take you a long time to do it and you might bust your thumb or you might bend a nail.  A nail gun is going to do it.

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Scott Christian: get it done in a.

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Scott Christian: repetitive repeatable motion with the same quality of every nail going in with less chance you're gonna bust your thumb.

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Scott Christian: um and think about that, with an API.

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Scott Christian: Well repeatable you're going to improve your compliance by having your system.

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Scott Christian: submit the repeatable parts of those manifests off.

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Scott Christian: Reduced  user error, reduced data entry to problems.

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Scott Christian: it's reliable, you know you can build the build the API in the json offline and then upload it later on when you're back online.

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Scott Christian: So, these provide flexibility, just like that.

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Scott Christian: So why do we use json for the same exact reason we use rest widely adopted standards means more people can use it are implemented service, a lot of tools available to support developers.

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Scott Christian: So, and nearly every tool set available can interact with our rest API so Jason so when we get to the DEMO William Nicholas wrote.

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Scott Christian: His code in Python.

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Scott Christian: We developed the e-Manifest in Java, David Graham use JavaScript for something he was testing with.

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Scott Christian: visual basic 

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Scott Christian:  and there's many commercial off the shelf products they use API, and a lot of those commercial offices chip sell products currently integrate into e-Manifest.

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Scott Christian: So, there's a lot of support for this out there.

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Scott Christian: let's go to the over that excellent.

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Scott Christian: Well, I've gotten through the first section of our agenda we're on to the second section, which is the current manifest workflows.

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Scott Christian: And I'm going to go through the fully electronic and then I'm going to go through the hybrid.

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Scott Christian: workflows.

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Scott Christian: So.

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Scott Christian: Thank you.

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Scott Christian: So, the background of this scenario is a fully electronic shipment where the TSDF company is arranging shipment for a generator that can use fully electronic manifest this this generator has at least to prepare.

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Scott Christian: The generator recently submitted notifications for their quadrennial sqg renotification and the TSDF needs to update their systems information regarding customer a lot of generators, if you have not updated your internal databases, this is also a public service announcement.

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Scott Christian: But a lot of generators going through this this year and then in this section I exercise, we will update a waste line and take the manifest to receipt so we're trying to create a.

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Scott Christian: Strict straightforward but typical workflow.

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Scott Christian: And if you could please.

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Scott Christian: Go to the next slide perfect So the first thing you need to do, and this has been remembered back several slides and several slides before that authentication.

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Scott Christian: So, the API key and key is sent and the token an expiration is sent back so that the in this case the tsp of customer service representative.

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Scott Christian: is using their in-house corporate system and either knowingly or unbeknownst to them, they will communicate to record info and the system will send the API key.

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Scott Christian: To progress info and then broke rental sent back to the system, the token so they can do their work in the expiration of that token.

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Scott Christian: Which is about 20 minutes.

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Scott Christian: The authentication the system's going to set this and that information.

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Scott Christian: Here are the examples, so the top example is a client URL example you can use the command line you'll see it's a request you get you're sending your request to.

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Scott Christian: record info and you're going to send in your API key and key of course API key are fake API keys never share your API keys are like your username password you know, keep those protected.

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Scott Christian: And then below that we have the Python code that William wrote so you can go look at his code, this is on our github site there's a link to it in the presentation, so please go check that out and we'll go right to the function that you need to learn about authentication.

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Scott Christian: Next, we have to find the generator so like I said they had recently updated their notification and the.

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Scott Christian:  TSDF customer service representative.

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Scott Christian:  needs to update  their system, so they send the request there's they've already been authenticated they send that request with such search criteria and refer info sends back the site or sites.

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Scott Christian: That was that match that search criteria and then using their interface, they can see what they need to update.

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Scott Christian: what's different about this slide is going to be on most of the subsequent slides is we've provided you with the with the json for each request and each response remember back several slides when I was talking about an API it sends a request and the other systems event back response.

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Scott Christian: You can use this to match so you're you know that your code is working and, of course.

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Scott Christian: Provided Williams function for the site search.

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Stephen Donnelly: And  quick note all the others sample json's they will be uploaded to the docket they're going to be  text files, but you will have all that sample json that you'll see in the presentation those will be available on the docket for you to download and use yes.

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Scott Christian: Thank you very much and they're also on github as well.

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Scott Christian: So is William's code.

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Scott Christian: So, creating a fully electronic manifest again same as before there's an example of a fully electronic manifest that your system can send.

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Scott Christian: And then you'll get a response back with.

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Scott Christian: The manifest tracking number.

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Scott Christian: Again, the Python code, does the same thing.

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Scott Christian: Now we're into the transaction, so the transporters phone has authenticated.

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Scott Christian: They are at the generator site.

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Scott Christian: They get there and they realize a couple of the drums aren't ready for.

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Scott Christian: for transport, they need to stay behind, for whatever reason, so the transporter using your phone APP or.

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Scott Christian: Third party service providers that they update manifest and either knowingly or unknowingly them they send the request the system's response sends a confirmation back the manifest has been updated.

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Scott Christian: With those new terms, so this will be able to see that see the difference and send the update you could also send that update as the as the as the format of.

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Scott Christian: How we built these very flexibly, but so now that that has happened, the transporter is now getting the manifest ready to sign.

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Scott Christian: And they send we have this service, called the UI links over some user interface service so from their application they send a service request and response with a universal resource locator basically a.

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Scott Christian: A link.

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Scott Christian: to sign that manifest and then that link can be sent from the transporters phone directly to the.

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Scott Christian: generator if they're using the same system, the same system email text.

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Scott Christian: However, it's wants to be developed and that generator click on that link go in be taken directly to the sign page review the manifest click quick sign and then.

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Scott Christian: The manifest is ready for the transporter do the same thing.

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Scott Christian: You go to the next slide.

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Scott Christian: And on this transport does the same thing they do not have to send it to anyone, because it's coming to them, they go into the system login  are taken to that review page click quick sign and now they're ready to start their engine and go on the road.

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Scott Christian: except for one thing, go the next slide.

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Scott Christian: printing out the D O T shipping paper, so the transporter.

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Scott Christian: After all, the signatures have can go request he manifest get her get the manifest attachments back, they have that.

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Scott Christian: PDF and, in this case, this manifest happens to be a one page manifest the prints off on an eight and a half inch by 11 pieces of paper, not the dot matrix printer not an impact printer not a printer that needs to be kept in certain degrees temperature just a.

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Scott Christian: portable printer.

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Scott Christian: or they could ask the generator to do it and print out that eight and a half 11 paper that he didn't have a printer with goes in the cab of the truck and the truck goes to the.

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Scott Christian: TSDF for signature.

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Scott Christian: And the TSDF user.

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Scott Christian: After the transporter has delivered the waste goes in sends the UI link service and indeed for these examples we're going to focus on quick sign.

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Scott Christian: There is another step under the Cross media electronic reporting rule Steve touched on that a little bit earlier and pretty much all know the finalization of manifest and signing, but this case we're going to just do a quick sign, because that can be done by.

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Scott Christian: The TSDFs and this TSDF user at the dock at the gate is quick signing the man.

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Scott Christian: So that was the fully electronic now it's hybrid and hybrid can be set up, from the beginning, but this time I wanted to throw a little bit extra.

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Scott Christian: curveball in the scenario so it's going to be the same exact scenario.

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Scott Christian: At least for the beginning part.

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Scott Christian: And, but then the generate when the  transporter shows up at the generator site, none of the registered signers are there and another public service announcement it's a reason to get people registered so if somebody.

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Scott Christian: The signers not there, then.

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Scott Christian: Somebody can register, but fortunately, the person there is.

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Scott Christian:  DOT trained, and they can sign the manifest, so they can do the hybrid portion of the manifest.

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Scott Christian: And finally, we're going to update the manifest type to hybrid and take the manifest through the final submission.

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Scott Christian: that's good so same exact scenario is before the tsp of customer service representative sends the manifest to manifest and RCRA info sends back a manifest tracking number.

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Scott Christian: same exact function that William wrote and used on the previous one, was being reused to that on this on this example.

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Scott Christian: right but.

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Scott Christian: Like I said.

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Scott Christian: The.

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Scott Christian: transporter gets there, and even though the generator confirmed with themselves, and they have already printed out their single piece of paper.

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Scott Christian: With everything they need to do they did their.

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Scott Christian:  shipment properly and the generator on site has signed on paper.

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Scott Christian: The transporter needs to make that adjustment, so now the transporter Luckily, the generator had planned ahead and add that piece of paper it printed.

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Scott Christian: takes that paper signature information and uploads it along with the change from fully electronic to hybrid.

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Scott Christian: And they send that up to up to recommend to a system.

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Scott Christian: And we now have a hybrid manifest.

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Scott Christian: So now, the transporter already has a generator information agent in there, though, the next likely.

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Scott Christian: chance, where he has a generator for information in there they're going to send you a link service, just like we saw in the previous example same example that nail gun example.

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Scott Christian: And they get back the URL to sign in their  application their tablet and they click sign and manifest is on its way so forget updates.

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Scott Christian: And this is the same exact processes before they get the updates they send it to a printer these a generator printer or another truck but it isn't an eight and a half by 11 piece of paper.

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Scott Christian: What we all use every day, not a 5-copy manifest.  So, it can go on the truck and, finally, just for, even though we are using quick sign for this.

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Scott Christian: These examples I sent it to the bulk sign page instead so you can send it to different pages, the link server so you can send to the dashboard in this case we're sending to the bulk sign also send it to an individual manifest without having to go on this.

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Scott Christian: there's a lot of flexibility there, please check out the github site.

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Scott Christian: Definitely check out Williams code and with that I'm going to hand this presentation over to him.

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William Nicholas: Thank you Scott Steve's gonna roll a DEMO for us here in a moment, and that will cover the transactions covered in the scenarios, we just saw but you know kind of live through the DEMO.

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William Nicholas: The DEMO the associated json and the PowerPoint as previously mentioned will be on the docket for this meeting.

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William Nicholas: runtime for this DEMO it's about 16 minutes, and you know, as I mentioned it'll cover what you've just seen it won't cover every possible scenario and.

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William Nicholas: I'll describe a bit more about some considerations for your review, on the other side of the DEMO.

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William Nicholas: I'll encourage you to turn up your volume the DEMO is a little bit quieter, and I want to make sure you all can hear it so take a moment to turn up your volume and Steve go ahead and roll the DEMO.

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Hello everyone, welcome to the you manifest Python services DEMO.

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you've just heard from us explaining the details of how to use our restful API services to.

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Set up sign and distribute links for generators transporters TSDFs to process a manifest foil electronically, and then additionally in a hybrid status.

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What we're going to show you here is a live DEMO of all of that process demonstrated in Python using our e manifest package, enabling you to with your own Python installation.

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conduct this business and utilize services to take advantage of the benefits of fully electronic manifests on hybrid manifest and to make the process easier faster for you.

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So, just like the slides, we have the same objectives we're going to set things up authenticate and then generate sign and update a full electronic manifest However, unlike the slides we're going to start with the Python specific setup.

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To do that we're first going to bring in the record info teams, he manifests package This assumes that you've installed it ahead of time using you know for Python your pip install process or you can also do this via condo.

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Next, we're going to authenticate our account This assumes ahead of time that you have enabled API access in record info do you have questions about that feel free to consult the documentation or send us an email.

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But I'm going to feed the variables for API ID and our API key into the system if you're working in an environment where you have multiple users, you can certainly set that up to be variable and to require somebody to put it in each time.

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Next, we're going to authenticate using the manifest package we've used the authentication command, as well as the variables we've just selected to authorize us for the pre prod instance.

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That tells us with this authentication successful message that we are ready to go, and then we can access anything that our record info account has permissions for.

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Start we're going to find our generator and we're going to put in some search parameters here the name and the zip code that we'd like, in this case Jen.

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here in our own tenant to.

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And that might take a second depending on how many parameters you put in and how much it has, to come back.

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But after we send out that command, you'll receive something that looks like more or less than excel spreadsheet what's called a pandas data frame if you're familiar with Python and that will include whatever is relevant to your search parameters.

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So, we've got the one back that's you know, an EPA side ID our test generator right here and.

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that's when we would create you know we'd use some of this information to populate our manifest so we would need to generate a json file I'll show that here.

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And this includes information about say that generator right there.

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That we can pull from.

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This output here.

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And we save this file as a json object.

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Once we've saved that file here in our local folder we can use the SAVE command again and the manifest package to send that to record info and we get back confirmation that it's been saved and we get our manifest tracking number.

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That manifest tracking number, we can use to populate other commands but for now we're going to use it to populate an update so again we're going to open up a json file that we've created you know we've put in the manifest tracking number that we got back from step four.

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and any other information that we would want to update.

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Once we've done that, we use the update command to send that out to record info and to make some changes we've gotten confirmation here that says that that has been successfully updated.

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Now, as the generator I can generate the I'm going to generate the link to sign that.

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So, we've generated our link I can go ahead and click that and because I'm logged in to record info it will open up the manifest.

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And if we scroll all the way down to the bottom, here I can go ahead and click sign because I've got the permission for that.

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And that's great so now returning here, I can generate a link.

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That I'll go ahead and send to the transporter.

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Now that I've gone ahead and done that, I'm going to pass things over to Scott serving as our transporter and will demonstrate how someone working through the transporter could sinus even from their phone.

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Thank you, William and as the transporter I'm taking this link I could have clicked on it, but I'm going to paste it in and I'm brought to the pre-production login screen.

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Where I click on scotty Christian rapper for.

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sign.

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And I'm in here I'm taking directly to the sign screen, I can review the manifest that I've just worked on, with my client the generator scroll all the way through.

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right here, I can now click quick side.

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Last me some questions quick  sorry and.

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00:54:37.830 --> 00:54:39.630
There we go I'm taking back to.

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The screen, where I can see a class that I had just signed.

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I will send it back to you.

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Great and now that our transporter has signed, I can get any of the details I want I'm going to call out for updates so I'm going to use the manifest package, the get attachments function and I'm going to plug in the manifest tracking number that we have for this manifest.

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And you'll see here over in my folder structure as I refresh that.

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PDF and json come back with additional detail about that manifest and so, if I want to review that here in the process that's available to me.

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But we're going to assume that I'm comfortable with things and I'd like to finish it up and send it for receipt at the.

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TSDF so again I'll generate a link and this time this link will be specific to the TSDF and I'm going to send that over to David, who is serving as our receiving facility.

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Thank you, William as the TSDF now I now have that URL link that.

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Williams application generated for me so I'm going to paste that here.

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Only again, you could just click it but.

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for purposes of this demonstration already have that URL copied to your clipboard so at this point, I can go through, I can specify the information generator information that generator ids correct transporting information all the stuff.

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Like down again, all the way down to the bottom, just like Scott, did I can click sound like such.

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confirm that all the information is again correct.

337
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Now that manifest has been signed by the generator transporter and it doesn't even receive facility, I'm going to hand it over to him.

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So, thanks to the work of David Scott and myself we've now set up the Python environment authenticated our account.

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found the generator created update and distributed for signature our electronic manifests and along the way we called out for updates and got those files back to us all with the simplicity of the restful API is and the repeatability of a Python process.

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Now we're going to take some time and show you how this might work with a hybrid manifest.

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And now we're going to demonstrate the hybrid manifest that we again discussed on the slides previously, this is similar to the foil electronic process but.

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Has a couple of notable differences will start out the same way, we will bring in the manifest package, and then we will authenticate ourselves with record info.

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Now that we've successfully done that, we will again pass a json object containing the information about our manifest to record info.

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And again, we've got a successful message telling us it's been saved and the manifest tracking number that's associated with this manifest now.

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However, now we want to change the manifest to a hybrid because we've heard from our partners in this process that this one will need to be a hybrid.

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And, like the full electronic process, we can accomplish a change, using the update command and, in this case, we're going to send the update Jason, but we've now changed the submission type to hybrid.

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So, when we send this out.

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we've updated the manifest and the status and record info will show as hybrid.

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Now that we've updated, I'm going to go ahead and generate a UI link and send that directly to Scott, who is serving as our transporter.

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Thank you get William so this new user is using a tablet they've already from there from their tablet and the APP that they're they built on their  company built on their tablet.

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The transporters taken directly to the link for the manifest that was just updated from electronic to hybrid.

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I log in.

353
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And I see of the test by and I see yes, it's now a hybrid manifest nice scroll down and there's a lot here, because the review is kind of big manifest.

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and

355
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generator and we see oh perfect so Jim tester, who is the generator and they  signed, and I can now quick sign this manifest so the information was uploaded.

356
01:00:06.210 --> 01:00:17.940
And I can now go and click quick sign see the transport knowledge we receive materials quick sign again and I'm taking back to the dashboard.

357
01:00:19.650 --> 01:00:21.840
And then I drive away and.

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01:00:24.240 --> 01:00:24.930
hand it back to away.

359
01:00:32.460 --> 01:00:40.830
Excellent thanks Scott, and so, if I want to get an update on that and confirm that we've gotten our transporter signature.

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01:00:41.550 --> 01:01:03.420
I can go ahead and run that get attachments command and you'll see here and my file structure that I've gotten of information and this you manifest json object is going to include information about the manifest the status of it, and you know who has signed.

361
01:01:05.370 --> 01:01:09.090
In this case, I
I've just seen that Scott has signed up.

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01:01:10.320 --> 01:01:26.220
So excellent now it's ready to be signed once it gets to the TSDF and so I'll generate a link specifically for our receiving facility and I'll send that over to David, who is serving as our receiving facility.

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01:01:28.920 --> 01:01:37.470
All right, thank you, William again so for purposes of this demonstration I'm already logged in as our tsp.

364
01:01:38.670 --> 01:01:43.350
And then I click on that link that Williams DEMO application semi.

365
01:01:45.690 --> 01:01:48.750
pulls up a new tab again I'm already signed in.

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01:01:50.160 --> 01:02:05.400
I can see, I have the option to compare sign or click sign these manifest that were just sent to me I'm going to go ahead and click science and that's all I needed the moment I click both ears like doll or.

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01:02:06.510 --> 01:02:10.830
filter or just sign manifest that I want to sign.

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01:02:12.330 --> 01:02:18.000
Also review if you'd like but for purposes of the day we're just going to go ahead and click sign both of these manifests.

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Again, confirm the information is correct.

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01:02:24.090 --> 01:02:26.580
And our electronic manifest now complete.

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01:02:29.070 --> 01:02:40.680
Thanks David so now we've managed to show you both fully electronic and hybrid options to complete the manifest process.

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01:02:41.280 --> 01:02:54.060
all the way from the initial creation of the manifest through the signature at the receiving facility in this case, using Python and the restful APIs.

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Of the record info system enabling you to leverage new tools and reduce the friction allowing you to have a more pleasant rapid and efficient manifesting experience.

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we're going to come back to our presentation now, but if you have questions about this, we encourage you to reach out to us individually or to check out our github at github.com slash us EPA slash manifest.

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Thank you.

376
01:03:45.210 --> 01:03:58.920
William Nicholas: Thanks for watching our DEMO everyone, and as I note here in the slides, this is a sample scenario, it covers one set of transactions, you know handled one way with one technical approach.

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01:03:59.760 --> 01:04:09.030
William Nicholas: But the power of the APIs their flexibility, you can use Python you can use JavaScript you can use Java, you can use your own systems.

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William Nicholas: Your systems and your processes may be different, but your developers can adapt these API's to meet your current systems, your current processes using what you already have and what you already do.

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William Nicholas: A couple of regulatory points to note the receiving facility will need to finalize manifests and sign them as complete their to be compliant.

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William Nicholas: But the UI link service you saw is one touch API that can help you with that and another point, while the generator signs that hybrid manifest on paper it's the electronic representation of the signature, that is uploaded to the system via the API.

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01:04:47.400 --> 01:04:56.310
William Nicholas: As I note in the DEMO if you have questions, we encourage you to reach out, we encourage you to make submission to the docket and also to check out our github.

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01:04:57.120 --> 01:05:03.930
William Nicholas: If you have further questions, we can handle that later and for now I'm going to pass it over to test fields, who will open up our.

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William Nicholas: You know feedback and Q&A session.

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Tess Fields: Good afternoon, everyone, we have a good amount of time set aside in this next session to discuss some questions that we want to pose to you and answer questions that you all have put in the chat.

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Tess Fields: So, first, I will go through the questions that we would like to get your feedback on today.

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Tess Fields: So, I'll read through these questions first and we'll take comments on them or other related topics, so, if you would like to speak, please hit the raised hand button.

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Tess Fields: And I will go through in the order in which your hands are raised and unmute you and then after that we'll get to the Q&A session for questions in the chat.

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Tess Fields: So, our two questions for the section are do you think improved understanding of the existing electronic manifest workflow similar to today's presentation would encourage users to adopt electronic manifests.

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Tess Fields: And what types of assistance from EPA, for example, would be needed for users to adopt the existing electronic manifest process.

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Tess Fields: So, if you have thoughts on either of those questions or additional topics, please raise your hand I see, we have one hand raised by Teresa Colabella.

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01:06:30.930 --> 01:06:32.010
Tess Fields: If you'd like to.

392
01:06:33.390 --> 01:06:35.610
Tess Fields: provide any feedback right now Teresa that's.

393
01:06:37.200 --> 01:06:40.230
Theresa Colabella: I think it was an accident that I just went over my hand.

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Tess Fields: that's okay.

395
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Tess Fields: No worries.

396
01:06:43.050 --> 01:07:04.620
Theresa Colabella: um but I will say that I do believe it's kind of confusing um these people, not necessarily are not necessarily it people, and it may seem that they would have to employ their it department to be able to work on this or to accepted so would improve understanding.

397
01:07:06.360 --> 01:07:23.820
Theresa Colabella: Of the workflow similar to this yeah, but I think the it people really need to be involved at the facilities more than necessarily the way you know the end user or the waste generator.

398
01:07:25.590 --> 01:07:26.760
Tess Fields: Thank you.

399
01:07:45.570 --> 01:07:50.130
Tess Fields: still not seeing any hands raised if anybody would like to.

400
01:07:51.720 --> 01:08:03.420
Tess Fields: provide feedback, or we can jump into the written Q and A and, if you think about questions that you want to ask verbally or think about feedback that you would still like to give feel free to continue raising your hand.

401
01:08:05.670 --> 01:08:06.960
Tess Fields: If you have anything you want to add.

402
01:08:41.070 --> 01:08:47.400
Tess Fields: Bryan would you like to start addressing some of the questions in the Q& A box, as people think about their feedback.

403
01:08:47.970 --> 01:09:03.600
Bryan Groce: Sure, so they're only a few questions here so hopefully once I read these questions and provide answers folks can follow up with the questions that Tess asked, so the first question in the chat.

404
01:09:06.330 --> 01:09:16.080
Bryan Groce: asks are any hybrid manifest being submitted, or are they being counted as electronic manifest versus data plus image or image uploads.

405
01:09:17.370 --> 01:09:18.540
Bryan Groce: I think the.

406
01:09:20.730 --> 01:09:32.400
Bryan Groce: The demos that we just gave pretty much answers this question how our electronic manifests originate.

407
01:09:32.910 --> 01:09:46.920
Bryan Groce: In the system, however, the hybrid manifest is printed out as a hard copy for the unregistered generator and that manifest is signed by the generator and kept for their records.

408
01:09:48.540 --> 01:09:50.580
Bryan Groce: The next question.

409
01:09:52.200 --> 01:10:03.540
Bryan Groce: This mentions that the slides 21 through 39 covered the manifest elements, but what about if our LDR stuff is still in paper.

410
01:10:04.830 --> 01:10:14.190
Bryan Groce: The system only collects the RCRA manifest it does not collect any other.

411
01:10:16.200 --> 01:10:25.950
Bryan Groce: documents that are required under our federal rules, so those LDR documents would have to be kept as hard copies on file at the.

412
01:10:26.970 --> 01:10:27.900
Bryan Groce: facility's site.

413
01:10:29.190 --> 01:10:43.200
Bryan Groce: And the next question I'm going to read out and ask Scott to sort of clarify. For the hybrid manifest is there any image of the paper manifest with a generator's signature uploaded at the time the shipment leaves the generator's site? 

414
01:10:45.210 --> 01:10:51.930
Scott Christian: There is not so that that is like you like you said just answering the other question it's a.

415
01:10:53.010 --> 01:10:58.800
Scott Christian: it's a record keeping requirement to keep that piece of paper, the only thing that is uploaded like William said, is the.

416
01:11:00.900 --> 01:11:05.370
Scott Christian: Electronic representation that person's name and the date they signed.

417
01:11:07.590 --> 01:11:08.130
Bryan Groce: Thanks Scott.

418
01:11:10.560 --> 01:11:13.830
Bryan Groce: And that's all I have, for now, and the see maybe there's more.

419
01:11:17.670 --> 01:11:22.440
Bryan Groce: No, at this point there aren't any other questions in the chat.

420
01:11:24.150 --> 01:11:25.380
Bryan Groce: Actually, I see.

421
01:11:27.060 --> 01:11:28.050
Tess Fields: just got one.

422
01:11:28.290 --> 01:11:29.040
Bryan Groce: just got one more.

423
01:11:31.470 --> 01:11:33.870
Bryan Groce: This is for the development team.

424
01:11:35.370 --> 01:11:46.830
Bryan Groce: And effort to increase adoption of hybrid and full electronic manifests submissions are there any plans to allow electronic signatures not via the RCRA info websites, such as SMS signing.

425
01:11:51.390 --> 01:12:00.480
Stephen Donnelly: That is something we're going to be, this is the yeah so that's going to be something we're going to be covering in the next town, I think we're gonna take a break in a few minutes we're gonna be covering up some options.

426
01:12:01.710 --> 01:12:12.300
Stephen Donnelly: On sort of alternate electronic signature workflows and processes that's gonna be a be the next section, and as far as sort of.

427
01:12:12.840 --> 01:12:25.500
Stephen Donnelly: You know what exactly what you are recommending if you don't see anything and the presentations that sort of hits that on the head, please do submit your ideas either.

428
01:12:26.370 --> 01:12:41.010
Stephen Donnelly: You know what and the third one, the concluding sessions is listening to stakeholder ideas comment verbally there, or if you don't have time or feel called don't feel comfortable doing it Please submit that your proposal into the docket.

429
01:12:44.190 --> 01:12:44.670
Bryan Groce: Thanks Steve.

430
01:12:45.960 --> 01:12:54.900
Bryan Groce: So, this was just received another chat question it's a follow up to the hybrid question what percentage of electronic manifests are submitted as hybrid.

431
01:12:55.590 --> 01:13:13.980
Bryan Groce: And so, again we mentioned earlier in the presentation that less than 1% of all manifest submissions are electronic. I don't know if we have a breakdown of what is considered to be electronic or hybrid but let's say it's less than 1%.

432
01:13:18.240 --> 01:13:19.110
Stephen Donnelly: up after the break.

433
01:13:20.940 --> 01:13:23.640
Bryan Groce: And that's all I have here is from the chat.

434
01:13:27.900 --> 01:13:37.770
Tess Fields: If you could go back to our discussion questions just give people a chance to read them quickly again if anyone would like to raise their hand and chime in.

435
01:13:39.270 --> 01:13:41.370
Tess Fields: And also, just a friendly reminder that.

436
01:13:42.480 --> 01:13:44.730
Tess Fields: As we said at the beginning, we have a docket.

437
01:13:46.170 --> 01:13:56.040
Tess Fields: That we have linked to on our website, and you can submit written comments, which we strongly encourage you to do either on things that we've discussed today or comments in general.

438
01:14:12.660 --> 01:14:17.640
Tess Fields: Okay, we have one person raising their hand. Nicole go ahead, please.

439
01:14:18.780 --> 01:14:21.510
Nicole McClish: hi, yes, I'm maybe I'm getting ahead.

440
01:14:22.770 --> 01:14:32.550
Nicole McClish: But in the example used, you know that was a very plain white you know, waste management transporter goes to a single generator picks up waste and goes direct to TSDF.

441
01:14:33.780 --> 01:14:43.140
Nicole McClish: What about in the case of you know, a large hazardous waste company that's transporting materials to hubs.

442
01:14:43.860 --> 01:14:57.870
Nicole McClish: And so, your hubs are building loads where you're going to have 40 plus manifests, you're going to have a different transporter can pick that up so you've got 40 manifest with 40 different generators is the expectation that.

443
01:14:58.950 --> 01:15:05.130
Nicole McClish: That transporter would have to sit down and pull up each individual manifest assign them within RCRA info if they were all created electronically.

444
01:15:10.050 --> 01:15:14.850
Tess Fields: Thank you for that question. Scott or William would you like to quickly unmute.

445
01:15:17.580 --> 01:15:22.740
Scott Christian: I appreciate the question, it's kind of a reason.

446
01:15:22.740 --> 01:15:24.600
Scott Christian: We did the bulk sign.

447
01:15:25.890 --> 01:15:26.790
Scott Christian: Quick sign.

448
01:15:29.070 --> 01:15:31.620
Scott Christian: Up link service example in the.

449
01:15:33.390 --> 01:15:49.230
Scott Christian: In the in the DEMO and in the presentation, so one of the nice things about the UI link service is it has filter object, so your system which knows those manifests that your driver needs to sign can upload to.

450
01:15:51.060 --> 01:15:53.700
Scott Christian: Process those manifest tracking numbers.

451
01:15:53.760 --> 01:15:59.430
Scott Christian: And then they'll see in the bulk sign page curated list to quick sign all of those.

452
01:16:00.000 --> 01:16:00.990
Nicole McClish: things at once okay.

453
01:16:01.020 --> 01:16:03.150
Scott Christian: yeah, so that that's in there.

454
01:16:05.430 --> 01:16:05.730
Scott Christian: yeah.

455
01:16:08.460 --> 01:16:17.790
Scott Christian: yeah, if you have any questions, please follow up on that one but yeah it was actually, I think your predecessor was requested that functionality me.

456
01:16:19.020 --> 01:16:19.350
Scott Christian: Thank you.

457
01:16:19.770 --> 01:16:20.460
Nicole McClish: Okay, thank you.

458
01:16:26.310 --> 01:16:35.820
Tess Fields: Great Thank you and we also just had a comment come into our Q&A box which I'd like to read, since this meeting is being recorded, so if anyone that's watching.

459
01:16:36.690 --> 01:16:44.070
Tess Fields: This in the future, someone commented as a broker the workflow is clear, we are not aware of any TSDFs that are willing to accept.

460
01:16:44.400 --> 01:16:54.780
Tess Fields: Electronic manifest from us if we had TSDFs willing to accept electronic manifest we created, we would start utilizing full electronic, thank you for that comment.

461
01:16:55.920 --> 01:16:58.320
Tess Fields: I don't know if anyone on our team would like to.

462
01:16:59.460 --> 01:17:00.270
Tess Fields: respond to that.

463
01:17:13.620 --> 01:17:28.290
Stephen Donnelly: I think it stands on its own so I'm looking at the percentage of electronic to live, so the to the electronic manifest we have a subsection of hybrid or fully electronic so I'm pulling those numbers are right now, though, should be up and just.

464
01:17:56.760 --> 01:18:02.670
Tess Fields: So, if we don't have any other comments, I know Steve is pulling our proportion of.

465
01:18:04.320 --> 01:18:07.560
Tess Fields: types of filing, but we are going to have a short break.

466
01:18:09.510 --> 01:18:15.720
Tess Fields: And then reconvene for our policy options section at the end, the barbaric.

467
01:18:18.750 --> 01:18:31.140
Tess Fields: So, we will reconvene at 230 please get some water, get some snacks and thank you all for listening and engaging and we'll See you in 10 minutes.

468
01:29:44.490 --> 01:29:57.630
Amanda Kohler: So welcome back everyone from our break, my name is Amanda Kohler before we move into this next section I just wanted to check with Steve and or Scott and if we wanted to follow up on any of the questions from the previous section.

469
01:30:00.540 --> 01:30:09.000
Stephen Donnelly: Yes, yes, so there was a question about percentages of electronic manifests as well as the.

470
01:30:09.360 --> 01:30:19.650
Stephen Donnelly: The hybrid method, so we all know, fully electronic is, when all the handlers listed on the manifester signing electronically, and then the hybrid is where all the transporters are.

471
01:30:20.610 --> 01:30:37.110
Stephen Donnelly: received so you're assigning electronically, so we have received a 6 million manifest total one and of those 6 billion manifests we've got roughly 20,000 electronic manifests and we have a.

472
01:30:38.250 --> 01:30:46.590
Stephen Donnelly: We have the majority of as are fully electronic so 12,000 out of those 20,000 are fully electronic.

473
01:30:47.880 --> 01:30:59.820
Stephen Donnelly: And the remaining 7000 are hybrid so let me just do some math right so that's so I believe that's roughly I would say, two thirds are fully electronic and a third are hybrid.

474
01:31:01.080 --> 01:31:02.460
Stephen Donnelly: In terms of the electronic then.

475
01:31:08.550 --> 01:31:10.560
Stephen Donnelly: we'll go back to disappear now.

476
01:31:12.870 --> 01:31:20.910
Amanda Kohler: Okay, thank you so I'm hoping we get more comments and feedback, maybe we're all saving them for this part of the meeting.

477
01:31:21.840 --> 01:31:33.330
Amanda Kohler: But you know the previous discussion discussed our current electronic manifest workflow as it exists in our e-Manifest system, and this next section will discuss what could be.

478
01:31:33.840 --> 01:31:47.070
Amanda Kohler: potential future options that we can consider so we'll have an introduction after this agenda slide and so will set the stage on expectations, specifically where we are in our planning phase here.

479
01:31:47.940 --> 01:31:57.810
Amanda Kohler: We will talk about applicable statutory and regulatory requirements certainly any scenario that we consider must meet the requirements of the e-manifest act.

480
01:31:58.320 --> 01:32:13.350
Amanda Kohler: With respect to regulations, we are open to policy changes, where it makes sense to do so, although any scenarios that already fit within existing manifest regulations may be preferred or

481
01:32:13.950 --> 01:32:21.810
Amanda Kohler: You know, have an advantage in that role, making change takes time and so options that already fit within the existing regs will be faster to implement.

482
01:32:22.890 --> 01:32:31.470
Amanda Kohler: And then Steve and I are going to do a volley, pickle a ball, that's what comes to mind here with going through some workflows.

483
01:32:31.890 --> 01:32:37.770
Amanda Kohler: As well as applying the e-manifest act and existing regulatory framework.

484
01:32:38.250 --> 01:32:50.160
Amanda Kohler: And then we'll talk about valid enforceable electronic signatures and valid enforceable is a key term here, because that language is used in the existing definition of electronic signatures under our regulations.

485
01:32:51.000 --> 01:33:04.590
Amanda Kohler: So, with that David Thank you okay so setting the stage here during our last advisory board meeting we discussed our FY 22/23 program priorities and user fees.

486
01:33:05.610 --> 01:33:11.490
Amanda Kohler: Part of our program priorities is our long standing and highest party goal to increase adoption of electronic manifest.

487
01:33:12.240 --> 01:33:18.570
Amanda Kohler: As part of that discussion, the board recommended to us that we consider broadening the concept of a fully electronic manifest.

488
01:33:19.110 --> 01:33:30.360
Amanda Kohler: that we continue the pursuit of regulatory change when necessary, and we also consider integrating e-manifest with hazardous waste industries private manifesting systems, and this is really to capitalize.

489
01:33:30.960 --> 01:33:39.510
Amanda Kohler: On the success that we've seen to date with image plus data manifest coming in through system-to-system connections like Scott mentioned earlier.

490
01:33:42.720 --> 01:33:48.780
Amanda Kohler: Okay, so we are committed to in our response to the Advisory Board to do this to.

491
01:33:49.410 --> 01:33:59.760
Amanda Kohler: To look at future potential options and also to engage stakeholders earlier on in our planning of these options and so that's what brings us together today.

492
01:34:00.360 --> 01:34:14.160
Amanda Kohler: We also have a meeting next week, which will be the same, the same agenda so and I think I already talked about these two simple lists, but I just want to make sure we're all clear on expectations, so you know what we're about to talk to is.

493
01:34:15.480 --> 01:34:20.490
Amanda Kohler: Early concepts, so they have not been fully vetted internally within the Agency.

494
01:34:21.090 --> 01:34:26.550
Amanda Kohler: The purpose of these meetings is to get input from you to help inform what direction we go.

495
01:34:26.910 --> 01:34:35.970
Amanda Kohler: go in, in terms of really fleshing out certain options that we would bring back to the Advisory Board, so what  you hear or not they're not.

496
01:34:36.420 --> 01:34:45.240
Amanda Kohler: there's no decisions, yet there's no formal proposals it's really just getting early input, so that we can make a formal proposal at a later date with the Advisory Board.

497
01:34:46.770 --> 01:34:49.110
Amanda Kohler: Okay next slide please.

498
01:34:50.430 --> 01:34:59.100
Amanda Kohler: Alright, so now we're going to go into the statutory and regulatory framework and there's really three components here and we're going to start with the e-manifest Act, which requires EPA.

499
01:34:59.550 --> 01:35:13.710
Amanda Kohler: To establish a hazardous waste electronic manifest system that may be used by a new user and then the act goes on to define user and we put a screenshot here on the slide, but I wanted to direct your attention to Section 5(B)(i).

500
01:35:14.970 --> 01:35:25.530
Amanda Kohler: So, a user is any person that elects to use the system, the system being the e-manifest system to complete and transmit an electronic manifest format.

501
01:35:27.780 --> 01:35:28.830
Amanda Kohler: Next slide please.

502
01:35:32.490 --> 01:35:43.140
Amanda Kohler: Now we're at the EPA regulations, so this is the regulatory side of things, here we have put some language from section 262.24.

503
01:35:43.740 --> 01:35:52.530
Amanda Kohler: This language talks about how electronic manifest or the legal equivalent to paper manifests, but I wanted to direct your attention to section (a)(2) here.

504
01:35:53.040 --> 01:36:08.880
Amanda Kohler: Which is that any requirement in these regulations to give provide send forward or return to another person, a copy of the manifest is satisfied when electronic manifest is transmitted to the other person by submission to the system (EPA's e-manifest system).

505
01:36:10.590 --> 01:36:23.310
Amanda Kohler: And last point here is this language that we that we have in 262.24 this is in the generator part of the regulations, but we have similar language for transporters and TSDs in those parts of the regs.

506
01:36:26.610 --> 01:36:34.530
Amanda Kohler: Okay last component of these sessions for and regulatory framework is the definition of electronic manifest signatures and 262 25.

507
01:36:35.850 --> 01:36:43.800
Amanda Kohler: Here we define electronic signature methods for a manifest to be two things one, a legally valid and enforceable signature.

508
01:36:44.610 --> 01:36:56.010
Amanda Kohler: Under applicable EPA and other federal requirements and two, a method that is designed and implemented in a manner that EPA considers to be as cost effective and practical as possible for the users.

509
01:36:58.560 --> 01:37:16.080
Amanda Kohler: So main takeaways here going through the Statute and the regs so under the e-manifest act a user must use the system, the system being our e-manifest system to complete and transmit and electronic manifest format and we can talk a little bit more about that.

510
01:37:17.700 --> 01:37:28.530
Amanda Kohler: Second takeaway requirements in the regulations to give provide send forward or return to another person, a copy of the manifest are satisfied only by submission to e-manifest.

511
01:37:29.790 --> 01:37:37.500
Amanda Kohler: And then the third piece is that electronic signature methods for e-manifest must be legally valid enforceable and cost effective and practical.

512
01:37:38.490 --> 01:37:49.800
Amanda Kohler: And so, what we're going to do here is I'm going to turn it over to Steve and we're going to walk through four scenarios and then in each of these scenarios we're going to come back to these takeaways and.

513
01:37:50.850 --> 01:37:54.960
Amanda Kohler: tell you exactly how we're leaning on whether these requirements would be satisfied.

514
01:37:59.130 --> 01:38:12.360
Stephen Donnelly: All right, thank you Amanda and I do want to mention, so this slide deck there is a there's a law appendix in the slide deck about a lot of this policy, information, so we have a lot of information there.

515
01:38:12.750 --> 01:38:18.720
Stephen Donnelly: And that's a plug for the team for putting in all this hard work and it's also a.

516
01:38:19.380 --> 01:38:33.030
Stephen Donnelly: reminder to our users, that you know if we don't have you know we want more we want some feedback these Q and A section session so if we're not getting some questions, we're going to make sure that we read all those slides in grace.

517
01:38:33.390 --> 01:38:37.800
Stephen Donnelly: in great detail and I'll have to do I'll be able to do so, my accents and.

518
01:38:38.430 --> 01:38:39.780
Amanda Kohler: or make you watching eagles' game.

519
01:38:39.960 --> 01:38:41.670
Stephen Donnelly: make us legal boy that's.

520
01:38:42.600 --> 01:38:42.870
yeah.

521
01:38:45.180 --> 01:38:55.590
Stephen Donnelly: That is that fair, that is not fair to anybody, especially but alright, so in light of our advisory board's recommendations.

522
01:38:57.000 --> 01:39:01.230
Stephen Donnelly: We see for theoretical options and conceptual workflows.

523
01:39:03.120 --> 01:39:18.120
Stephen Donnelly: For  our for what we're going to talk through today, so this doesn't mean there's more than four conceptual workflows, but it certainly doesn't mean there's less because we have four here so Essentially, we have the existing electronic manifest workflow.

524
01:39:19.710 --> 01:39:31.110
Stephen Donnelly: There then we have the workflow where the user, will have the electronic manifests outside of the e-manifest system and then upload everything at the end.

525
01:39:32.220 --> 01:39:36.240
Stephen Donnelly: Then for number three, we have a third-party system that.

526
01:39:37.260 --> 01:39:43.320
Stephen Donnelly: That is connected that sort of is in the ether between the e-manifest system and the industry system that.

527
01:39:44.520 --> 01:39:50.640
Stephen Donnelly: uploads the signatures throughout and that  third party will be advancing the manifest.

528
01:39:51.090 --> 01:40:07.710
Stephen Donnelly: And then we also have a fourth conceptual workflow where the user uploads the signature through out in the e-manifest system advances, so this would be outside of the system non final signature and it would be, it would be moved.

529
01:40:08.970 --> 01:40:23.670
Stephen Donnelly: So a manifest would be signed outside of the e-manifest system, but the system would get that signature and we would continue to work for them we're going to go into more detail than that, but that is our conceptual.

530
01:40:25.170 --> 01:40:41.160
Stephen Donnelly: Those are conceptual workflows we're going to go through today so go to the next slide all right, and I have actually I've screen-capped this little this little while this little graphic will be be very helpful because we're going to go through the statutory regulatory requirements, however, this.

531
01:40:42.210 --> 01:40:48.720
Stephen Donnelly: This neat little these little arrows that David Graham put together will really help bring this.

532
01:40:49.800 --> 01:40:57.810
Stephen Donnelly: To bring us into sort of reality, so we have are the blue is the transfer of manifest data or the change.

533
01:40:58.740 --> 01:41:19.620
Stephen Donnelly: And stats and the red one is the signer updated manifest data and this little Pen is the signature icon and that shows, whether it's that's where the signature is taking place, and then these fun little shapes right here, those are the generators, which is some sort of.

534
01:41:20.850 --> 01:41:28.110
Stephen Donnelly: kind of looks like the Sydney Opera House but, and then we have a transporter right here, and then we have our TSDFs so those are.

535
01:41:29.310 --> 01:41:38.970
Stephen Donnelly: Those are our three those were three sort of transactions, so you know there's a lot of degrees in the system, but yeah so Essentially, this is what we're doing.

536
01:41:40.410 --> 01:41:50.250
Stephen Donnelly: All right, here we are, this is our existing electronic manifest workflow so right now we have the manifest that is created in the system.

537
01:41:51.810 --> 01:41:53.670
Stephen Donnelly: And then we have.

538
01:41:55.170 --> 01:42:09.630
Stephen Donnelly: The manifest created in the system, the generator signs and it moves along to the transporter, the transporter signs and then that has moved along to another, transporter and then eventually to the receiving facility and then manifest is complete.

539
01:42:12.390 --> 01:42:16.650
Stephen Donnelly: So, everything takes place on the in the inside of the e-manifest system.

540
01:42:22.860 --> 01:42:40.620
Stephen Donnelly: Alright, so for this system, who needs to be registered, this is everyone, everyone needs to be registered to do that, so you need to go, create a user account, you need to request say access and you need to obtain at least an e-manifest preparer level access to do the quick sign.

541
01:42:42.090 --> 01:42:53.700
Stephen Donnelly: And to sign that manifest the user will log into RCRAi info they would navigate to that electronic manifest and if they paid attention in the first part of the presentation or checked out that.

542
01:42:54.240 --> 01:43:07.710
Stephen Donnelly: The helpful material, we have on github or in the docket soon they could send a  user interface link directly to that and that user to shorten the task, and they would click the fun quick sign button and.

543
01:43:08.310 --> 01:43:21.570
Stephen Donnelly: Also, I want everybody to know that e-manifest in RCRA info is a is a device neutral application so you can do this on a tablet you can use on a smartphone you can do this on a computer.

544
01:43:22.890 --> 01:43:24.990
Yes, those are the three things you can do.

545
01:43:27.000 --> 01:43:30.180
Stephen Donnelly: And then you click quick side to advance the manifest.

546
01:43:33.810 --> 01:43:46.020
Amanda Kohler: Okay, so given Steve just described our current electronic manifest workflow as it exists in the e-manifest system, you would expect a lot of check marks here for the statutory regulatory requirements so.

547
01:43:46.710 --> 01:44:04.470
Amanda Kohler: Clearly, we're using the system to complete and transmit electronic manifests we are transmitting to the other person by submission to the system and then for electronic signatures, we are using valid enforceable electronic signatures in our e-manifest system, however.

548
01:44:05.940 --> 01:44:10.410
Amanda Kohler: Since there are less than half a percent of total manifest that represents electronic manifests.

549
01:44:11.100 --> 01:44:25.860
Amanda Kohler: It is reasonable to conclude that there are questions regarding whether or electronic signature method is cost effective and practical for users, so you see us acknowledge that here with a with a question mark and so that let's talk about some other options Steve.

550
01:44:31.500 --> 01:44:44.640
Stephen Donnelly: happy to talk about other options so yeah let's refer back so remember that the Blue arrow is the transfer of manifest or changing status and the red arrow is the signer updated manifest date.

551
01:44:45.150 --> 01:44:52.920
Stephen Donnelly: So, this right here, and Amanda, I have the mouse icon selected. Can you see the mouse moving around on the screen.

552
01:44:54.060 --> 01:44:54.630
Stephen Donnelly: You see anything.

553
01:44:55.020 --> 01:44:57.570
Amanda Kohler: I don't see it, I see mine, but not yours.

554
01:45:01.200 --> 01:45:03.060
Amanda Kohler: Oh, there are saw it, go back.

555
01:45:03.240 --> 01:45:03.840
Amanda Kohler: yeah, your.

556
01:45:03.930 --> 01:45:04.770
Amanda Kohler: there I saw it.

557
01:45:05.070 --> 01:45:05.700
Stephen Donnelly: Well, that's good.

558
01:45:05.760 --> 01:45:18.390
Stephen Donnelly: I think I saw it, but David Graham yeah so follow me on the right So yes, we have the user uploads a signature at the end, so this is in sort of broad terms, the.

559
01:45:19.200 --> 01:45:27.870
Stephen Donnelly: The method where a manifest would be created in the e-manifest system, so an industry system would say okay here are my here's the.

560
01:45:28.920 --> 01:45:35.520
Stephen Donnelly: you give me all the manifest data, and then it disappears from the e-manifest system, so it goes down to the industry system.

561
01:45:36.300 --> 01:45:41.940
Stephen Donnelly: And it goes through the workflow so it will go from the.

562
01:45:42.450 --> 01:45:56.100
Stephen Donnelly: To the transfer from the generator side to the transporters to the other transporters to all the system note of all the signatures on any changes or anything would be happening outside the system, the e-manifest system would not be part of any.

563
01:45:58.830 --> 01:46:16.740
Stephen Donnelly: Any part of a updates to that manifest and then at the end, where all the signatures are done, it would be sent back to the system as an electronic manifest signed, and then we would have all, then the then manifest will be there.

564
01:46:17.760 --> 01:46:18.930
Stephen Donnelly: Alright, so we go to the next slide.

565
01:46:23.130 --> 01:46:31.590
Stephen Donnelly: All right, so who needs to be registered on this workflow well, we only need the receiving facility registered on this workflow because all of the other handlers would be.

566
01:46:31.920 --> 01:46:43.050
Stephen Donnelly: Signing outside of the system, so they would not need a RCRA info account receiving facility, we need to have at least a site manager or certifier access to sign that CROMERR-compliant signature.

567
01:46:44.520 --> 01:46:50.970
Stephen Donnelly: And to sign users would use whatever widget they have outside of the system and.

568
01:46:52.230 --> 01:47:01.620
Stephen Donnelly: The no data would be transferred until the receiving facility would submit that manifest that final completed manifest to the EPA e-manifest system.

569
01:47:05.940 --> 01:47:21.840
Amanda Kohler: hey thanks Steve so scenario two which is different than scenario one because the electronic signatures are being captured outside of our system and uploaded at the end you know our really leaning here on this on this option is that.

570
01:47:23.040 --> 01:47:26.040
Amanda Kohler: it's challenged in terms of how it would satisfy.

571
01:47:27.060 --> 01:47:41.220
Amanda Kohler: The e-manifest act requirement to use the system, EPA's e-manifest system to complete and transmit electronic manifests and that's because in scenario two the completion is happening outside of the system, as far as on the regulatory side again.

572
01:47:42.420 --> 01:47:54.720
Amanda Kohler: we're finding it challenging to satisfy for how this scenario satisfies transmitting to the other person by submission to the system and that's because the transmittal to the other person is happening outside of the system.

573
01:47:56.130 --> 01:48:04.950
Amanda Kohler: Electronic signatures, you know we have question marks here because we are considering electronic signatures in this scenario that are outside of e-manifest system.

574
01:48:05.670 --> 01:48:15.360
Amanda Kohler: it's unclear at this point whether and how we would assure that electronic signatures are both valid enforceable and also a method that's cost effective and practical so.

575
01:48:17.190 --> 01:48:18.900
Amanda Kohler: Okay scenario three Steve.

576
01:48:19.770 --> 01:48:23.310
Stephen Donnelly: scenario three, this is a third party.

577
01:48:24.360 --> 01:48:33.720
Stephen Donnelly: All right, so we have a there's a third party is a third party this imagine a cloud of some sort that holds the manifest and a.

578
01:48:34.740 --> 01:48:48.840
Stephen Donnelly: I'll say like sort of a limbo between the e-manifest system and the industry system, so the manifest would be created in e-manifest, and it would go into this third-party system which will go into the.

579
01:48:50.820 --> 01:48:58.530
Stephen Donnelly: ether of third-party system, so there, there would do this, so it wouldn't be an industry system it wouldn't be the e-manifest system, it would be.

580
01:48:59.910 --> 01:49:03.120
Stephen Donnelly: somewhere else, yes, a third party.

581
01:49:04.290 --> 01:49:12.060
Stephen Donnelly: As we describe alright, so the system manifest will be created a system, we will go into the third-party data to bring up the laser pointer.

582
01:49:15.300 --> 01:49:16.770
Stephen Donnelly: Go back to the previous line.

583
01:49:18.360 --> 01:49:20.880
Stephen Donnelly: And you have, if you have the laser pointer to walk through the different steps.

584
01:49:22.200 --> 01:49:27.630
Stephen Donnelly: Right yeah so that manifest would go down and what would happen is we go to the generator site in the generator would.

585
01:49:28.440 --> 01:49:39.270
Stephen Donnelly: Go access that third party system through a smartphone or a computer or something, and they would sign and when that manifest is signed in that third party system, the.

586
01:49:40.140 --> 01:49:58.950
Stephen Donnelly: That third party system would communicate with tick tick the red arrow backup to the manifest system, so the other, the regulators stay at the state regulators, the other people in that party, the manifest would be able to see that manifest had been updated in the system.

587
01:50:00.120 --> 01:50:09.120
Stephen Donnelly: And when that man that signature gets shot up, it also moves along to the next transporter they would sign in that manifest signature would.

588
01:50:09.450 --> 01:50:27.000
Stephen Donnelly: shoot back up to the e-manifest system and it would go and go and go and go until we're at the end of the way so basically every time something changes on the manifest this third party would tell us and tell our States until all the people associated with the sites that something happened.

589
01:50:29.340 --> 01:50:30.540
Stephen Donnelly: To go to the next slide.

590
01:50:31.920 --> 01:50:41.520
Stephen Donnelly: So, who needs to be registered similar to our previous we would have the receiving facility registered so they can use that CROMERR-compliant signature.

591
01:50:43.830 --> 01:50:55.140
Stephen Donnelly: so, to sign the users must be able to access third party system by a verified communication email phone user accounts.

592
01:50:56.730 --> 01:51:12.450
Stephen Donnelly: and verification, for this is very important, it means they can access account it's not a verification of their ID, it's the verification that they can access, so these transporters and generators, they would be able, they would need to have access to that.

593
01:51:14.220 --> 01:51:15.150
Stephen Donnelly: Third party.

594
01:51:18.510 --> 01:51:18.900
system.

595
01:51:25.770 --> 01:51:33.360
Amanda Kohler: Oh, thank you so scenario three that Steve just walked through differs from scenario to in that scenario two had.

596
01:51:34.080 --> 01:51:46.650
Amanda Kohler: All the electronic signatures coming in with the manifest data at the end. Scenario three, however, has the electronic signatures coming in with the data throughout the process, so our early leaning is that this.

597
01:51:47.880 --> 01:51:55.920
Amanda Kohler: You know, could meet it could satisfy the e-manifest act requirement to use the system to complete and transmit electronic manifests.

598
01:51:56.670 --> 01:52:05.130
Amanda Kohler: You know, depending on ultimately what we determined to be transmit and what that means, as far as the EPA regulatory requirements.

599
01:52:06.060 --> 01:52:17.100
Amanda Kohler: Again, it's a little challenging to see how scenario three would be considered to transmit to the other person by submission to the system and that's because in scenario 3 the manifest advances outside of the system.

600
01:52:18.270 --> 01:52:31.770
Amanda Kohler: And then again similar to scenario two questions on electronic signatures that's because electronic signatures are being captured outside of EPA e-manifest and so whether and how we would determine valid enforceable cost effective and practical is an open question.

601
01:52:34.980 --> 01:52:36.000
Amanda Kohler: Alright, so scenario four.

602
01:52:36.930 --> 01:52:53.220
Stephen Donnelly: All right, scenario  four, four of four of our conceptual frameworks of the electronic signature workflow. So, this is the user uploads signatures throughout, so this is a synthesis of methods one, three and.

603
01:52:55.050 --> 01:53:04.050
Stephen Donnelly: Two I, these are this is um but its own thing, in a lot of ways as well, so here we are at the top, the manifest is created in the e-Manifest system.

604
01:53:05.190 --> 01:53:20.040
Stephen Donnelly: And what would happen is that the manifest would be signs the generator would sign outside of the e-manifest system, however, that information would be that outside the system.

605
01:53:21.060 --> 01:53:31.080
Stephen Donnelly: information would be sent back to the e-manifest system and the manifest would progress along to subsequent transporters the transporter to be signing.

606
01:53:31.980 --> 01:53:37.470
Stephen Donnelly: In their industry system, and that would be sent back, and it would then it would go down to the next transporter.

607
01:53:38.040 --> 01:53:48.900
Stephen Donnelly: And that transporter would sign in their industry system and it would get sent back up and then this and then eventually go to the received so now, this might look.

608
01:53:49.410 --> 01:54:01.470
Stephen Donnelly: A little bit familiar or, this is one of our considerations when we had one of our advisory board meetings on electronic signatures sometime in 2019 or 2020, we had a lot.

609
01:54:02.430 --> 01:54:15.600
Stephen Donnelly: And this was part of the I think this is called at the time the one-person registered solution, so we have one person registered along each site for an industry system and that person would be able to send back.

610
01:54:16.500 --> 01:54:30.600
Stephen Donnelly: Information, this is that thanks to David Graham for fleshing this out a little further, but one of the they sort of the principal idea here is, we would have people registered we go to the next slide and so people can read it.

611
01:54:31.950 --> 01:54:49.830
Stephen Donnelly: We would have each party would have a site manager, with an API ID and key registered along the way, so that generator that transporter the receiving facility would have a site manager with an API ID and key, and they would.

612
01:54:51.840 --> 01:55:07.230
Stephen Donnelly: And several individuals could sign using that site managers ID so the API that we would build services out that an industry user, so we go down to sign would click sign in their system so, however, that would be.

613
01:55:08.670 --> 01:55:27.840
Stephen Donnelly: However, they would have it in their industry system or whichever manifest the person at the dock or in the car would click sign or whatever they would tell their industry system, I signed this manifest and through their industry their site API site API ID.

614
01:55:29.490 --> 01:55:35.370
Stephen Donnelly: That signature information will be sent back to the EPA system and the manifest would advance so.

615
01:55:36.510 --> 01:55:39.300
Stephen Donnelly: The user agenda what's this use the generators.

616
01:55:40.830 --> 01:55:53.820
Stephen Donnelly: The generator would do something would do something in their generator system to let that generator site manager know they have signed that manifest they've acknowledged receipt.

617
01:55:54.630 --> 01:56:04.020
Stephen Donnelly: And it's time for that generator site manager to let the e-manifest system know this manifest is ready for the transporter to sign.

618
01:56:11.730 --> 01:56:14.250
Stephen Donnelly: And so on it's so good.

619
01:56:15.780 --> 01:56:20.520
Amanda Kohler: Okay, so applying the statutory and regulatory requirements to scenario four.

620
01:56:21.840 --> 01:56:30.120
Amanda Kohler: We think this scenario of the you know scenarios 2 through 4 is probably the best fit with what we what the current requirements are.

621
01:56:30.750 --> 01:56:45.090
Amanda Kohler: scenario four which differs from scenario three because in scenario four the manifest is actually advancing through our system, and so we are using the system to complete and transmit electronic manifest also using the system to transmit to the other person.

622
01:56:45.780 --> 01:56:52.110
Amanda Kohler: Again, question marks for electronic signatures just because scenario for like scenarios, two and three.

623
01:56:52.590 --> 01:57:02.160
Amanda Kohler: does consider capturing electronic signatures outside of the e-manifest system, and so, whether and how to define those as valid and enforceable and cost effective and practical is, it is an open question.

624
01:57:04.020 --> 01:57:14.610
Amanda Kohler: and actually, we've been talking a lot about valid and enforceable let's unpack those concepts and I'm going to turn it over to Tess Fields to describe some hallmarks of valid enforceable electronic signatures.

625
01:57:18.180 --> 01:57:28.800
Tess Fields: Thanks, Amanda, yeah exactly, so we have talked about how valid and enforceable is the language used into 262.25 about how about electronic signatures.

626
01:57:29.250 --> 01:57:35.700
Tess Fields: So, what does that really mean and what does that mean in terms of other systems potentially capturing electronic signatures?

627
01:57:36.150 --> 01:57:52.050
Tess Fields: So, the CIO has put out a guidance document of five hallmarks that are typically considered parts of a valid and enforceable signature, and this is not something we have formally adopted but, rather, we want to walk through these because we think it provides good guidance of what is needed.

628
01:57:54.840 --> 01:57:55.260
Tess Fields: Next slide.

629
01:57:58.380 --> 01:58:12.000
Tess Fields: So, the first hallmark is the form of signature itself. Electronic forms of signatures can include symbols, such as a typed name, a digitized image of a written signature, a shared numerical code, a biometric identifier,

630
01:58:12.750 --> 01:58:24.330
Tess Fields: sounds such as a voice recording, processes such as using a mouse to click I agree, or the process of entering your private key to apply a digital signature.

631
01:58:25.290 --> 01:58:32.700
Tess Fields: And these don't provide an exhaustive list of the forms of electronic signature but illustrates the variety of options that are available.

632
01:58:35.700 --> 01:58:45.120
Tess Fields: The second hallmark is the intent to sign of the signer so in electronic transactions merely applying a sound symbol or process.

633
01:58:46.020 --> 01:58:52.590
Tess Fields: doesn't necessarily make it a legally binding signature, it must be implied with the intent to assign so when designing a.

634
01:58:53.370 --> 01:59:07.260
Tess Fields: Signing process to evidence and then tend to sign it's important to distinguish from intent to sign, and the reason for signing, for example, applying a signature versus simply writing your name into a form.

635
01:59:07.980 --> 01:59:20.430
Tess Fields: So, the overall signing process should be designed to minimize the risk that signers could legitimately claim later that they applied on an electronic form of signature without realizing its legal binding significance.

636
01:59:24.900 --> 01:59:25.470
Tess Fields: Next slide.

637
01:59:38.970 --> 01:59:43.440
Tess Fields: I'm not sure if it's frozen on my side but I'm still on slide seven.

638
01:59:45.090 --> 01:59:48.090
David Graham: we're on "Association of Signatures to the Record".

639
01:59:48.630 --> 02:00:05.790
Tess Fields: Oh, sorry I just jumped ahead on my own notes, thank you, so the third hallmark is association of signature to the record so I'm just us with a paper signature electronic signatures are required to be attached to or associated with the right of the record been signed.

640
02:00:07.290 --> 02:00:18.510
Tess Fields: And the two aspects of this issue are that the signer must have the opportunity to review the entirety of the record before signing it and to understand the parameters of the record that he or she is signing.

641
02:00:19.290 --> 02:00:27.930
Tess Fields: And the electronic signature must be linked to the record of being signed for an electronic signature to be equivalent to a signature on a paper document.

642
02:00:29.010 --> 02:00:42.570
Tess Fields: The signature that constitutes the electronic signature must be tied to the record and must allow someone to later determine that the record has been signed, so they must be tied together in some way.

643
02:00:43.980 --> 02:00:44.490
Tess Fields: Next slide.

644
02:00:46.740 --> 02:00:51.840
Tess Fields: The fourth hallmark is identification and authentication of the signer.

645
02:00:52.320 --> 02:01:03.240
Tess Fields: So, by definition, a signature must be the act of a specific signer and you have to be able to tell that the  signature was applied by whoever said that they signed it.

646
02:01:03.690 --> 02:01:08.040
Tess Fields: So, this requires establishing a link between an identified person and the signature.

647
02:01:08.940 --> 02:01:26.100
Tess Fields: Other security processes procedures may be used to accomplish this objective, for example, the signers identity may be authenticated as part of an overall process of obtaining access and signing into a website or an electronic resource that includes the record to be signed.

648
02:01:28.440 --> 02:01:40.140
Tess Fields: And the last hallmark is the integrity of the record, so the usability admissibility and prove ability of assigned electronic record requires procedures to be undertaken.

649
02:01:40.500 --> 02:01:48.510
Tess Fields: To ensure the continuing integrity of both the electronic record and its electronic signature following completion of the signing process.

650
02:01:48.990 --> 02:01:54.000
Tess Fields: And that's a matter of providing appropriate data security for both the record and the signature.

651
02:01:54.840 --> 02:02:07.800
Tess Fields: The concern regarding integrity flows from the fact that electronic records are easily altered in a manner that is not detectable so steps must be taken to ensure that the document that was electronically signed remains.

652
02:02:08.550 --> 02:02:12.990
Tess Fields: intact and it's not later altered, which would make the signature, no longer valid.

653
02:02:14.940 --> 02:02:30.540
Tess Fields: So, with that we're going to go back into another discussion section and Q&A section so similar to last time I'm going to go through and read the discussion questions that we have provided.

654
02:02:31.650 --> 02:02:46.950
Tess Fields: We actually have two slides of discussion questions here so I'll actually read through all of the questions first so take note of you know, things that might interest to you and then anyone who has thoughts on them can raise their hands and again I'll go through.

655
02:02:48.210 --> 02:03:04.050
Tess Fields: In order of who raise their hands first like last section So what are your thoughts on allowing users to capture and upload electronic signatures in terms of its likelihood to increase electronic adoption.

656
02:03:05.550 --> 02:03:13.170
Tess Fields: previously discussed electronic signature method options and the extent they would encourage adoption.

657
02:03:13.740 --> 02:03:30.030
Tess Fields: whether and how, for example in guidance we define valid and enforceable electronic signature for electronic signatures captured outside of a manifest whether we adopt the CIO guidance for valid and electronic valid and enforceable signature.

658
02:03:34.050 --> 02:03:40.290
Tess Fields: Whether EPA should be responsible for ensuring that industry systems meet requirements and, if so, how.

659
02:03:40.950 --> 02:03:47.580
Tess Fields: Whether EPA should be concerned about ensuring the manifest isn't altered between dock workers and site managers.

660
02:03:48.180 --> 02:04:01.950
Tess Fields: And whether EPA should require simultaneous direct connection upload to the manifests compared to allowing users to save on their system for some time before uploading and prior to advancing the manifest.

661
02:04:02.520 --> 02:04:12.360
Tess Fields: And what are potential offline impacts, so I know that is a lot we just went through a lot of information, and these are a lot of questions so.

662
02:04:13.650 --> 02:04:19.830
Tess Fields: please feel free to raise your hand or put comments in our Q&A box and.

663
02:04:22.230 --> 02:04:26.070
Tess Fields: I will go through, and call on you, so that we can have a lively discussion.

664
02:05:12.930 --> 02:05:17.790
Tess Fields: also feel free to chime in about thoughts on our proposed.

665
02:05:19.380 --> 02:05:28.320
Tess Fields: workflow options are, if you have questions about regulations or statutes are happy to hear it if you'd like to raise your hand.

666
02:05:51.960 --> 02:05:52.710
Tess Fields: All right.

667
02:05:54.540 --> 02:05:55.020
Tess Fields: Nick.

668
02:05:56.070 --> 02:06:03.630
Tess Fields: Thank you for raising your hand and please feel free to unmute yourself hello, can you hear me? Yes, I can.

669
02:06:04.200 --> 02:06:19.290
Nick Taglianetti: Great I was the one that posted the question on this topic earlier in the meeting I'm a developer, I actually built the client application for our company cleaners that sends manifests to the EPA.

670
02:06:20.010 --> 02:06:30.810
Nick Taglianetti: And the capturing of electronic signatures, has been the biggest hurdle for us, and this is mostly in the case of transporters.

671
02:06:31.290 --> 02:06:47.190
Nick Taglianetti: They often don't have smartphones or Internet access, and so what I would like to propose, which I think false between your scenario three and scenario for would be a way to sign electronic manifests.

672
02:06:47.880 --> 02:06:59.550
Nick Taglianetti: Using SMS text messaging so with that in mind, what would be the best way to accomplish that.

673
02:07:00.660 --> 02:07:17.970
Nick Taglianetti: From a regulatory standpoint, because I know that site managers are the ones really given the API credentials, so if that's the case with the transporter that driver be signing, on behalf of the site manager.

674
02:07:19.050 --> 02:07:27.840
Nick Taglianetti: Or would there be a way that we could sort of designate them to have their own unique credentials to sign with.

675
02:07:35.760 --> 02:07:37.770
Stephen Donnelly: hi this is Steve we.

676
02:07:37.830 --> 02:07:48.090
Stephen Donnelly: See, we proposed something similar to a sort of a text message or email signature to the advisory board that when we.

677
02:07:49.440 --> 02:07:54.570
Stephen Donnelly: Forget sometimes these 2019 or 20 2020 April 2020 meeting, we propose a.

678
02:07:55.920 --> 02:08:07.290
Stephen Donnelly: A sort of out of the system, via text message or email hey you have a manifest waiting for you click here to sign, so we need to be sort of a.

679
02:08:07.620 --> 02:08:23.580
Stephen Donnelly: sort of a binary yes, no and especially how would it work that how we discussed it would be the site manager associated with the transporter generator site or whoever's comparing the manifest would say, at a given time this are we, what we want this manifest to go to.

680
02:08:26.430 --> 02:08:46.590
Stephen Donnelly: tests and her this is her phone number 555 whatever and then at the time the shipment being scheduled the manifest test will get a notification on her phone saying hey hope you got your paper copy the manifest because you can say electronically right here and we'll move it along the.

681
02:08:48.000 --> 02:08:55.560
Stephen Donnelly: Whether it was, for some reason don't have the board the pole at the bottom and cut public commoners were reasonably.

682
02:08:56.640 --> 02:09:09.930
Stephen Donnelly: Okay, with that we actually have worked a lot of that a lot of that internally, and we would we have done some homework on that, so we haven't decided to do it or not, but if that is something that you are interested in.

683
02:09:10.530 --> 02:09:23.580
Stephen Donnelly: We do have on the EPA math on the EPA website at the materials from our past advisory board meeting so if you look at the White Paper from the April 2020 meeting, we go into detail on that and I think we would certainly not.

684
02:09:25.560 --> 02:09:32.460
Stephen Donnelly: We will not be upset if we needed to revisit that solution again moving forward, we haven't made a determination, yes or no.

685
02:09:33.030 --> 02:09:43.470
Stephen Donnelly: On automatic, but that is something we we have heard, especially from the multiple transport decided it would be easier for the manifest to go to them and would it be for the for them to go find them.

686
02:09:45.030 --> 02:09:57.990
Amanda Kohler: yeah, I'll add to that you know Steve mentioned the April 2020 when we discuss the text phone option, although at that time we were discussing our system pushing messages to individual.

687
02:09:59.070 --> 02:10:11.370
Amanda Kohler: phone numbers via text and so that was a challenge you would be to know you know what number was uniquely assigned to a certain person I'm actually hearing what you're what you're.

688
02:10:12.630 --> 02:10:15.600
Amanda Kohler: bringing up is similar to scenario for.

689
02:10:17.400 --> 02:10:18.060
Amanda Kohler: So.

690
02:10:19.230 --> 02:10:23.430
Amanda Kohler: In that scenario, maybe we can go back to this slide David if you don't mind.

691
02:10:24.480 --> 02:10:36.990
Amanda Kohler: So, what we're envisioning here is that the electronic signatures are being captured outside of our manifest system so we're at the early stages, no, no decisions here, but what we're saying is that hazardous waste companies.

692
02:10:38.220 --> 02:10:53.490
Amanda Kohler: Are  there, doing the electronic signatures at the dock by the driver, however, whatever method works for them pending any you know potential guidance that we may or may not consider as a program for what valid enforceable.

693
02:10:54.630 --> 02:11:05.820
Amanda Kohler: might look like, but that signature is being captured outside of our system, and so it is, it is you know, up to the companies to determine how  to do that.

694
02:11:06.240 --> 02:11:15.960
Amanda Kohler: What is what's part of our process that we really like about scenario for is that once that Doc river driver signs, you know, through the system, however, you determine the best way to do that.

695
02:11:16.650 --> 02:11:26.010
Amanda Kohler: The site manager is transmitting that information to our system using their unique API ID in key and so as part of that whole process of.

696
02:11:26.490 --> 02:11:35.040
Amanda Kohler: you're capturing the electronic signature the site managers, then transport transmitting that information to us throughout the process that whole process in itself.

697
02:11:36.480 --> 02:11:43.200
Amanda Kohler: You know gets to the authentication piece that test was talking about with those two you know the two-step process here so.

698
02:11:43.560 --> 02:11:51.780
Amanda Kohler: If that makes sense to Stephen Scott, you know, David, for you know, William, correct me if I got that wrong but that seems similar to what we were talking about scenario for.

699
02:11:53.250 --> 02:12:08.880
Stephen Donnelly: Well, it's hard to get anything wrong it's all conceptual but it sounds correct to me so very, very theoretical at this point, but if you do like I do that you're on the that's  how I envisioned it but part of the reason, what the right, the reason we're doing this is to.

700
02:12:10.350 --> 02:12:13.770
Stephen Donnelly: hear what your what industry and what would actually implement.

701
02:12:18.150 --> 02:12:22.950
Nick Taglianetti: yeah, that's that is pretty consistent with what my ideas were I mean.

702
02:12:23.460 --> 02:12:33.180
Nick Taglianetti: From our point of view, I'm sure somewhere we store all the phone numbers, I mean they're company issued phone numbers for transporters, so if there was a way we could relay that.

703
02:12:33.870 --> 02:12:41.730
Nick Taglianetti: sort of you know what phone numbers belong to a site manager relay that information to you guys, I think that that would.

704
02:12:43.020 --> 02:12:47.760
Nick Taglianetti: In my mind at least constitute the linkage that's needed.

705
02:12:49.650 --> 02:12:56.070
Stephen Donnelly: Okay, can I ask, can I ask a question from the sort of EPA, from sort of the e-manifest system standpoint.

706
02:12:57.240 --> 02:13:04.620
Stephen Donnelly: Now, especially when it comes to transporters in folks on the loading dock there is there is a lot of we've heard time and time again, there is a lot of.

707
02:13:06.660 --> 02:13:17.820
Stephen Donnelly: there's a lot of there's a lot of churn is slack in the markets, a lot of people come and go to these positions, but you know sort of in inside of the industry, this is just you your own individual experience and knowledge.

708
02:13:18.630 --> 02:13:25.110
Stephen Donnelly: Is there still a way that maybe you know who is working, when so you can get in touch with.

709
02:13:25.650 --> 02:13:39.990
Stephen Donnelly: person on the dock he will you know the specific phone number they're going to be at or you know driver X his email address, even though there's not like a set rotation, there is a sort of list you have where you have their contact information.

710
02:13:42.060 --> 02:13:55.770
Nick Taglianetti: Yes, I mean I'm just a on the it side, but I know I've worked closely with our transportation part of the business, and they do keep track of all of that, because it's important to the schedule.

711
02:13:57.570 --> 02:14:08.040
Nick Taglianetti: So, in terms of like I guess employee turnover I can't really speak to that, but I do I.

712
02:14:09.120 --> 02:14:16.380
Nick Taglianetti: I would imagine that drivers would have unique phone numbers and email addresses.

713
02:14:17.460 --> 02:14:20.370
Nick Taglianetti: Regardless of how long they've worked at the company or how short.

714
02:14:22.410 --> 02:14:28.260
Nick Taglianetti: So that that would be able to I mean be some indication of uniqueness.

715
02:14:29.430 --> 02:14:30.780
Nick Taglianetti: Of I think it's required here.

716
02:14:41.790 --> 02:14:50.850
Amanda Kohler: And also add, making David jump around this presentation, but if David can go to the format well I try signature, the first slide test one over.

717
02:14:52.440 --> 02:15:06.420
Amanda Kohler: And I keep hearing you know individual phones and you know, perhaps it could be no formal decisions could be simpler than that a typed name on a shared tablet on a shared phone so we're not necessarily.

718
02:15:07.470 --> 02:15:18.450
Amanda Kohler: I don't know if we're constrained necessarily by everyone, having a unique number that has to, then you know, have access to the manifest at the at the electronic signature at the manifesting.

719
02:15:19.530 --> 02:15:34.140
Amanda Kohler: Hazardous Waste company side, it could be more simple to meet your needs and then what we would have is the site manager with the unique ID and encrypted key then transmitting and thereby you know, affirming who signed that manifest at the at the docker or in the truck.

720
02:15:37.980 --> 02:15:40.380
Nick Taglianetti: yeah, I mean that was sort of my question is.

721
02:15:41.610 --> 02:15:58.500
Nick Taglianetti: Does the signature in this case, if it's an electronic signature does it need to come from the actual physical persons initiating it or does it can it basically all signatures be by on behalf of that person from the site manager.

722
02:16:00.360 --> 02:16:09.150
Amanda Kohler: yeah, we have certainly debated that for sure, and a lot of what we considered today we've heard through the Advisory Board process.

723
02:16:10.140 --> 02:16:18.600
Amanda Kohler: There is, you know the if you look at the manifest form the certifications the acknowledgement of receipt is very specific to the person that.

724
02:16:19.080 --> 02:16:28.140
Amanda Kohler: was involved in the preparation of the shipment, for example, so, so we are at this point, you know uncomfortable with the idea of just having some other person who's not even.

725
02:16:28.560 --> 02:16:34.500
Amanda Kohler: Aware of light of the packaging and you know it's not kind of physically near the shipment signing so.

726
02:16:34.920 --> 02:16:44.400
Amanda Kohler: In other words, were uncomfortable just having a site manager sign all the manifests so scenario for kind of brings these two together and has the electronic signature captured in some manner.

727
02:16:44.880 --> 02:16:55.710
Amanda Kohler: By the hazardous waste, companies and then having that information transmitted by the site manager to our system through that unique ID and key.

728
02:17:10.590 --> 02:17:11.670
Tess Fields: Thank you very much, Nick.

729
02:17:12.090 --> 02:17:13.290
Nick Taglianetti: Thank you very much.

730
02:17:19.410 --> 02:17:25.500
Tess Fields: And I would, encourage you again if you'd like to flesh out your thoughts more to submit a written comments or docket.

731
02:17:26.880 --> 02:17:27.510
Tess Fields: um.

732
02:17:28.770 --> 02:17:30.090
Tess Fields: Does anyone else have.

733
02:17:32.880 --> 02:17:38.160
Tess Fields: comments or questions or feedback, based on what we've discussed her these discussion questions.

734
02:18:01.980 --> 02:18:04.980
Tess Fields: we're ready to move on to our Q&A section.

735
02:18:09.120 --> 02:18:17.160
Tess Fields: Okay, so I'll hand it back over to Brian to walk through the various questions that have been put in our Q&A box.

736
02:18:18.540 --> 02:18:21.270
Bryan Groce: Thanks this so we don't have very many.

737
02:18:25.230 --> 02:18:26.700
Bryan Groce: Questions here.

738
02:18:28.230 --> 02:18:33.660
Bryan Groce: So, I'm just going to read through, I just want to remind folks this isn't the only opportunity for.

739
02:18:34.170 --> 02:18:46.590
Bryan Groce: People to comment you can submit your questions or comments to our docket following this meeting you have up to I believe December 30 to do so, so just want to reiterate that point, so the first.

740
02:18:47.610 --> 02:18:58.110
Bryan Groce: At least more of a comment, it says here that slide 50 presumes that Internet works across the nation it on that's not true and parts of the country.

741
02:18:59.400 --> 02:19:04.110
Bryan Groce: they're doing there may be some poor signal connection so not everyone necessarily would have.

742
02:19:06.480 --> 02:19:16.500
Bryan Groce: The access for you manifest us so based on this is a question that that we've been I guess sort of analyzing over the past.

743
02:19:17.790 --> 02:19:30.990
Bryan Groce: few months to a year and based on our IT team's analysis, I believe, and you guys can correct me if I am wrong here that roughly 98 of all generators.

744
02:19:32.190 --> 02:19:35.730
Bryan Groce: That are active RCRA info have.

745
02:19:36.870 --> 02:19:39.450
Bryan Groce: At least some type of Internet connection.

746
02:19:40.740 --> 02:19:51.960
Bryan Groce: And I don't know if, you guys want to explain that further and sort of explain what type they have, sort of a very basic type, not the high end, perhaps, but it's worth noting here.

747
02:19:53.460 --> 02:20:05.160
Stephen Donnelly: yeah so, I'll say this, I think, William did the we this has come up a few times, so we have a couple hundred thousand generators in the United States with EPA I think it's around 250 to 300,000.

748
02:20:05.730 --> 02:20:17.190
Stephen Donnelly: And so, 98% of those are GEO coding and eligible for an analysis of Internet coverage so of those of those 98% that we could.

749
02:20:18.630 --> 02:20:20.610
Stephen Donnelly: figure out where they are that are active.

750
02:20:22.830 --> 02:20:33.360
Stephen Donnelly: hundred percent have at least one business grade broadband so that includes satellite cell LTE offerings and.

751
02:20:34.680 --> 02:20:52.170
Stephen Donnelly: And then 99.9% of those sites that we could figure out where they are active sites where you figure out where they are 99.99% at least one traditional terrestrial broadband so that's a that's as you know sort of consumer.

752
02:20:53.550 --> 02:20:59.490
Stephen Donnelly: files or verizon a business cable modem option so.

753
02:21:00.990 --> 02:21:18.870
Stephen Donnelly: As far as far as far as this analysis will take us the generators, for the most part, are for are essentially they have Internet come now, the question is they, you know, was the manifest once that waste hits a.

754
02:21:20.010 --> 02:21:26.310
Stephen Donnelly: Was that way cicerone the drivers in you know the driver is in the hinterlands and there's no cell coverage so nothing.

755
02:21:27.300 --> 02:21:41.220
Stephen Donnelly: However, about where the ways is being picked up and where it's being where it's being dropped off, we found that they have Internet company you're able to go able to connect now if.

756
02:21:42.720 --> 02:21:48.990
Stephen Donnelly: The I think one of the reasons we're having this discussion and conversation, is that there are a lot of people with Internet coverage that.

757
02:21:49.050 --> 02:22:00.060
Stephen Donnelly: aren't doing electronic benefits I don't think the lack of Internet coverage is what's keeping the electronic numbers for being so low, however, we would like to put to bed, the notion that elect it's.

758
02:22:00.870 --> 02:22:12.720
Stephen Donnelly: it's generators that having Internet access, that is driving down the numbers and that will keep us from pushing this forward so we are we're coming to get you everyone's online all the time.

759
02:22:13.890 --> 02:22:32.850
Amanda Kohler: also add to that you know, in the event that you know online access goes down for a storm, or you know other reason temporarily we'd be interested in thoughts about adopting policy where you collect the signature perhaps at the hazardous waste companies.

760
02:22:33.930 --> 02:22:42.060
Amanda Kohler: side, but as long as you transmit to EPA, you know once access is established, or at least before the next.

761
02:22:43.080 --> 02:22:49.830
Amanda Kohler: Signature point you know would that be okay, and then that kind of that kind of handles a lot of the offline issues we think.

762
02:22:55.380 --> 02:22:56.340
Bryan Groce: Okay I'm.

763
02:22:57.660 --> 02:23:02.940
Bryan Groce: David, could you scroll up to slide 52 please.

764
02:23:05.370 --> 02:23:07.740
Bryan Groce: So, there's a comment that in terms of.

765
02:23:10.290 --> 02:23:10.710
Bryan Groce: Our.

766
02:23:11.850 --> 02:23:16.110
Bryan Groce: characterization of what the regulation says regarding.

767
02:23:18.270 --> 02:23:19.590
Bryan Groce: Maybe it's the next slide down.

768
02:23:21.690 --> 02:23:22.860
Bryan Groce: The word only was added.

769
02:23:24.180 --> 02:23:37.980
Bryan Groce: To the regulation referenced on the slide just want to make this one, to mention that that the commoner is correct and we will correct that slide for our next our next meeting on November 3.

770
02:23:38.400 --> 02:23:44.010
Amanda Kohler: Well, I actually have a thought on that so so correct for the main takeaways that.

771
02:23:44.250 --> 02:23:45.270
Bryan Groce: For the REG yes.

772
02:23:45.960 --> 02:24:03.450
Amanda Kohler: Right, so this is our takeaway so certainly these are you know early stages, and we encourage everyone to submit comments to the docket regarding our early findings on the requirements, but if David if you can flip up to the actual rank language.

773
02:24:05.010 --> 02:24:09.120
Amanda Kohler: I think it's 262 so right here, right here yeah, I think it's this one.

774
02:24:10.320 --> 02:24:13.470
Bryan Groce: It says it's in (a)(2).

775
02:24:13.920 --> 02:24:22.620
Amanda Kohler: Right okay so here's the actual REG language transmitted to the other person by submission to the system in our takeaway slide we said holy this is.

776
02:24:23.280 --> 02:24:35.250
Amanda Kohler: Great that's you know, so we haven't right in the regs that's our interpretation of it now, I think this commoner was you know, pointing out a nuance that we have, we have not covered, which is the hybrid so the hybrid manifests.

777
02:24:36.360 --> 02:24:43.170
Amanda Kohler: The generator science on paper and they're not conducting electronic manifest and so, in that case, if the generators are registered.

778
02:24:44.370 --> 02:24:46.740
Amanda Kohler: You know the TSDFs to send back.

779
02:24:46.740 --> 02:24:59.220
Amanda Kohler: certificate in hard copy to the generator I would say so that's an important nuance however hybrid manifest we have already provisions for those in or regulation, so I.

780
02:25:00.000 --> 02:25:15.090
Amanda Kohler: I applaud the comment because I brought out the REG so thank you for making me go to the regs here but um, but it is in that same section I think 262 24 and so it's already built in, so the So the question here is if we wanted to consider something other than a two.

781
02:25:16.290 --> 02:25:28.530
Amanda Kohler: Would we have to then do another red change  which we could you know that's something that we could consider as a program, but it would be, I think, at this point, early stages, a red change needed for that scenario.

782
02:25:30.480 --> 02:25:33.780
Amanda Kohler: So, I hope I hope that's a broader answer there.

783
02:25:36.210 --> 02:25:44.460
Stephen Donnelly: yeah, there are a wise, that is, a lot of ins and outs of the regs and there's a lot of grading material in the appendix, so we hope we.

784
02:25:45.150 --> 02:25:55.440
Stephen Donnelly: You know, as we go through this there's a lot of we've done a lot of homework but we are by no means shutting the door on any option or any proposal, we want to hear.

785
02:25:56.070 --> 02:26:04.890
Stephen Donnelly: And we want to hear you know, we want to hear stuff that can be defended through the statute of the regs and we don't want to hear anything great well, maybe I want to hear some.

786
02:26:05.340 --> 02:26:13.320
Stephen Donnelly: crazy proposals, but for the most part we we've given the information that we've been using to draw these assumptions are the information.

787
02:26:13.620 --> 02:26:22.980
Stephen Donnelly: That you have access to so we're all no one's hiding the ball on anything there's no secret there's no secret signature guidance, that we have that we're not sharing.

788
02:26:23.940 --> 02:26:31.080
Tess Fields: So, the commenter actually raised their hands to respond so I'm going to unmute them.

789
02:26:32.280 --> 02:26:33.540
Tess Fields: Now please go ahead.

790
02:26:34.650 --> 02:26:35.850
Noa Klein: Good morning, can you guys hear me.

791
02:26:36.540 --> 02:26:37.140
Stephen Donnelly: Yes, Hello.

792
02:26:37.410 --> 02:27:02.100
Noa Klein: Okay, so Hello I'm sorry I kept pressing enter I sent in three things that were really all part of the same thing and the main point that I really wanted to make is that I don't think that 40 CFR section 260 2.24 is imposing any requirement about transmitting.

793
02:27:03.960 --> 02:27:12.660
Noa Klein: A manifest to any party by submitting it to the system it's just saying that where there is an existing requirements somewhere else in the rules.

794
02:27:13.080 --> 02:27:27.240
Noa Klein: For any party to give provide send forward or return a copy of a manifest that that requirement can be met by the manifest being transmitted to that other party by submission to the e-manifest system.

795
02:27:28.950 --> 02:27:39.270
Noa Klein: And I think that that's important because, when you look at Option three I think it's actually it does better compared to.

796
02:27:41.100 --> 02:27:45.060
Noa Klein: The current regulations, then it's made out to look.

797
02:27:46.350 --> 02:27:52.290
Noa Klein: I'm not trying to endorse that option I'm just saying that it's extremely important.

798
02:27:53.370 --> 02:27:54.570
Noa Klein: Not to.

799
02:27:56.250 --> 02:28:08.220
Noa Klein: think that there's something required that's not really required if you're evaluating whether you have to make new rules as an important part of how good is this option or not, does that make sense.

800
02:28:09.000 --> 02:28:27.270
Amanda Kohler: yeah, absolutely and appreciate your thoughts on this, you know I just wrote reiterate yeah, this is a user early times for these concepts and so this is our early leaning on how the requirements would fit so we appreciate, you know different perspectives and no I hope you.

801
02:28:29.160 --> 02:28:38.100
Amanda Kohler: You know plan on submitting written comments, because I think those will be really helpful to consider in determining what we actually bring back to the Advisory Board on our requirements here.

802
02:28:39.480 --> 02:28:47.490
Noa Klein: yeah, I can definitely submit the same thing as a written comment if that's helpful for you guys and you know I always have opinions, so thank you for all your word.

803
02:28:47.640 --> 02:28:48.300
Amanda Kohler: Thank you.

804
02:28:49.410 --> 02:28:49.890
Bryan Groce: know.

805
02:28:54.120 --> 02:28:54.750
Bryan Groce: Okay, so.

806
02:28:56.220 --> 02:28:58.830
Bryan Groce: This is more of a comment, I guess, it is a question, but.

807
02:29:01.050 --> 02:29:04.950
Bryan Groce: The person that the individuals asking is, is there a way to download these documents, slides.

808
02:29:06.210 --> 02:29:13.770
Bryan Groce: That we presented here today as we mentioned earlier that the presentation slides are available in the docket and.

809
02:29:14.790 --> 02:29:24.000
Bryan Groce: I think in the following slides will have a summary and in terms of what the docket number is and where you can go to get the slide presentations and where you can submit your comments.

810
02:29:24.960 --> 02:29:38.310
Stephen Donnelly: gather the docket as well as our github site, as we have the stuff going up there as well, so the docket will have everything, including the video that we shared earlier, so the keep your eyes on the docket.

811
02:29:40.260 --> 02:29:41.310
lot of fun stuff going on there.

812
02:29:42.570 --> 02:29:42.990
Bryan Groce: Thanks. the.

813
02:29:44.250 --> 02:29:53.430
Bryan Groce: next question is the quick sign option considered a valid and  cost effective signature and you know, based on the.

814
02:29:54.990 --> 02:30:01.980
Bryan Groce: Current adoption rate I guess the answer at this point is, we just don't know at this time, if that's perhaps something.

815
02:30:02.430 --> 02:30:21.060
Bryan Groce: that's certainly it's valid in our in our estimation, but cost effective that's something that I guess requires further evaluation and not sure if the current central methods are prohibiting individuals from to sending any manifest but that's something we certainly have to.

816
02:30:22.290 --> 02:30:23.190
Bryan Groce: evaluate further.

817
02:30:28.800 --> 02:30:30.720
Bryan Groce: Okay let's see here so.

818
02:30:32.370 --> 02:30:33.420
Bryan Groce: The question.

819
02:30:34.710 --> 02:30:43.380
Bryan Groce: Can the signature process be similar to system-to- systems UPS or FedEx or retail stores developed that seemed to be a robust system.

820
02:30:45.300 --> 02:30:50.280
Bryan Groce: thanks for the comment and that's again that's something that we certainly can pursue.

821
02:30:52.740 --> 02:31:01.440
Bryan Groce: Alternative electronic formats and electronic signatures is something we certainly can evaluate and see if that's a viable option for your signatures.

822
02:31:02.130 --> 02:31:17.940
Amanda Kohler: yeah, similar to that I think scenario for and maybe even three you know what an individual company may choose to adopt, whether you know they're in the in-house system that they have now, or if they want to adopt something like ups or another signature.

823
02:31:20.220 --> 02:31:26.040
Amanda Kohler: Application software that's off the shelf that would all be part of scenario, three and four, I think right Steve.

824
02:31:33.210 --> 02:31:50.040
Bryan Groce: I think that's for the most part that's all I have in the Q&A box madness misspoke previously it's we didn't use the chat the chat is not activated for the question session but we're using the Q&A box, so wanted to be clear on that.

825
02:31:51.870 --> 02:31:52.260
Thanks.

826
02:32:24.930 --> 02:32:25.920
Tess Fields: So, I think.

827
02:32:27.000 --> 02:32:39.060
Tess Fields: Our next session or section is open discussion next slide David just about a final call for if anybody has any thoughts on.

828
02:32:40.980 --> 02:32:45.660
Tess Fields: Anything with presented today or comments or suggestions on things that they think.

829
02:32:47.490 --> 02:32:55.020
Tess Fields: You know, might be helpful or think that we should consider, so this is just a final opening of the floor if anybody would like to.

830
02:32:56.340 --> 02:32:56.970
Tess Fields: raise their hand.

831
02:33:05.730 --> 02:33:11.520
Tess Fields: No just wait two minutes in silence, if necessary, but then next slide will be about.

832
02:33:12.720 --> 02:33:15.120
Tess Fields: Submitting things to the docket and how to contact us.

833
02:34:32.790 --> 02:34:37.650
Tess Fields: Oh, David has raised his hand, so please feel free to unmute yourself David.

834
02:34:40.020 --> 02:34:40.410
David Comen: kind of.

835
02:34:42.420 --> 02:34:48.960
David Comen: kind of have a question on EPA's  thoughts of called targets for who.

836
02:34:50.160 --> 02:35:13.440
David Comen: Who in the regulated world or third party with do some of these options I work a lot with generators transporters and a little bit with TSDFs and looking at these the ability of a generator to implement I think any of these, as is almost homeless, Neil.

837
02:35:14.490 --> 02:35:18.210
David Comen: Maybe some transporters, but again, not very many of them.

838
02:35:19.350 --> 02:35:27.690
David Comen: And they're, these are the folks that are doing, most of the signatures, so I guess kind of looking for maybe some feedback on.

839
02:35:28.890 --> 02:35:35.910
David Comen: Who out here in a called an electron world would be designing and implementing these systems.

840
02:35:42.450 --> 02:35:49.500
Tess Fields: Thank you for that comment and question. Steve or Amanda or anyone on the team to address that.

841
02:35:56.610 --> 02:35:59.970
Stephen Donnelly: yeah, Thank you, thank you very much for that question, and that is a.

842
02:36:00.570 --> 02:36:12.810
Stephen Donnelly: that's one of the sort of the main considerations, we have when people you know mentioned, you know you're we're not just making a system just for FedEx or the post office we're making something for.

843
02:36:13.890 --> 02:36:19.200
Stephen Donnelly: 10 thousand of different companies and thousands of different individuals to use and.

844
02:36:20.760 --> 02:36:30.120
Stephen Donnelly: that's the that's the that's one of the primary drivers for why we're having this conversation, and you know how we how we built our system is essentially you know we have.

845
02:36:31.470 --> 02:36:37.050
Stephen Donnelly: we're sort of agnostic when it comes to how you're you know what you're using to send us the data.

846
02:36:38.550 --> 02:36:54.120
Stephen Donnelly: If the question is your and we have our structured data in the API's now the next step is how you're going to be sending us the how you could potentially send us the signature information because we understand we're not we're not so.

847
02:36:55.230 --> 02:37:07.260
Stephen Donnelly: or not so naive as a think that well, we could we could you know, having everybody operating the system, as is going to get us to 100% electronic manifest.

848
02:37:07.680 --> 02:37:17.670
Stephen Donnelly: So, what we're looking at now, especially with the options, you know, three and four is, as we have 85% of those 6 million manifests that come through.

849
02:37:18.390 --> 02:37:32.370
Stephen Donnelly: Through  data services, what can we do to move it along so those  manifest coming in through data services are also including signature information that meets that.

850
02:37:33.690 --> 02:37:35.070
Stephen Donnelly: meets those are the five.

851
02:37:36.450 --> 02:37:38.130
Stephen Donnelly: The five the five rules.

852
02:37:39.150 --> 02:37:48.270
Stephen Donnelly: And also, is cost effective impractical for the industry system so that's what we're that's what we're looking on in moving ahead and I understand there's a lot of.

853
02:37:48.720 --> 02:37:58.500
Stephen Donnelly: there's a lot of questions about you know, especially when it comes to the transporters how to how to bring those in and that's a that's an issue and we will you know.

854
02:37:59.340 --> 02:38:06.630
Stephen Donnelly: we're three years or three years into this and we're going to be around for a lot longer so that's something that we're going to move towards so we don't really have an answer.

855
02:38:07.290 --> 02:38:15.930
Stephen Donnelly: Other than our application is agnostic to it comes with how the data is coming what we want to do is sort of continue to.

856
02:38:16.800 --> 02:38:29.910
Stephen Donnelly: use that successful base accessible format we've got what we got 85% of that data coming in through services to bring in the signature information for that generator and transport and we don't think it's going to be.

857
02:38:30.990 --> 02:38:35.580
Stephen Donnelly: we're not exactly moving things up and you know, this is not impossible it's good it is.

858
02:38:36.630 --> 02:38:45.210
Stephen Donnelly: It is slow, it is it slow and you know sort of plotting work, but that is what we're here for.

859
02:39:01.680 --> 02:39:11.190
Stephen Donnelly: And then yeah so, I have a throwback a question to you, David is that um what, in your experience is.

860
02:39:13.020 --> 02:39:27.720
Stephen Donnelly: Leading you to believe that the generator and transporter ability to implement these options would not exist, particularly option options, where they're sending up knowing the say the name the name of a driver.

861
02:39:30.570 --> 02:39:31.950
David Comen: Well, I guess, and.

862
02:39:33.300 --> 02:39:49.110
David Comen: I have to confess I am completely out of my league when we're talking about the electronic aspects of this so that may be part of my limitation, but I'm dealing with I'm a truck driver sitting at the generator site.

863
02:39:50.970 --> 02:39:51.840
David Comen: And I've got a.

864
02:39:52.950 --> 02:39:59.460
David Comen: I've got a phone in my hand and I'm trying to figure out how to get to where I need to get to make a signature.

865
02:40:00.510 --> 02:40:12.030
David Comen: And drivers are in short supply, now, and I have somebody spends five minutes doing that and they throw the phone against the wall and go to work for another company then whole hazardous waste.

866
02:40:13.140 --> 02:40:22.710
David Comen: So I've got a little bit of a you know how do I facilitate for that individual and I guess part of my question and just my understanding is.

867
02:40:24.060 --> 02:40:34.530
David Comen: is, for example, if you have a transporter with 100 drivers do you think that they would have the resources to create an interface system.

868
02:40:35.910 --> 02:40:40.530
David Comen: Where their drivers to be able to do something easier, are you kind of looking for.

869
02:40:41.700 --> 02:40:55.350
David Comen: Third party to create a system that is funded by the menu by people that use it or funded by EPA, or you know kind of where does that that go.

870
02:40:56.370 --> 02:41:10.830
David Comen: tell you what my mental picture of something that works is a handheld device to just like what ups and FedEx use when they walk up to my door and they scan a package and an instruction to do something, and they do it and it's.

871
02:41:12.270 --> 02:41:13.590
David Comen: it's done very quickly.

872
02:41:14.880 --> 02:41:22.380
David Comen: So, if some kind of barcode or tracking number, which obviously we've got manifest numbers available is unique tracking number.

873
02:41:22.950 --> 02:41:30.720
David Comen: So, I'm kind of looking at something that says the driver walks in and gets handed a printed copy of the manifest that in each store is.

874
02:41:31.560 --> 02:41:43.500
David Comen: The shipping paper and he scans a barcode or a qr code up in the corner and it says there should be a tanker truck with 5000 gallons of ketone in it, and if this is right.

875
02:41:44.700 --> 02:41:48.180
David Comen: punch here and you've signed this is the transporter.

876
02:41:55.110 --> 02:41:55.410
David Comen: And that's.

877
02:41:56.160 --> 02:41:58.950
Stephen Donnelly: A that's very that is really very helpful.

878
02:42:02.700 --> 02:42:09.150
Amanda Kohler: And again, I'll point out, I don't think that's different necessarily from scenario for in that the.

879
02:42:09.570 --> 02:42:13.380
Amanda Kohler: companies can decide how they want to capture electronic signatures.

880
02:42:13.980 --> 02:42:18.960
Amanda Kohler: And then the trends middle would just be through the state on site ID manager site manager sorry.

881
02:42:20.700 --> 02:42:36.630
Amanda Kohler: So, it's um there's a lot of different ways to capture electronic signatures and that's why we took the time with  tests here to describe the hallmarks of the legal and enforceable electronic signatures, because a lot of different formats can count as electronic signatures.

882
02:42:45.150 --> 02:42:54.510
Amanda Kohler: And so, I think it would be helpful to is if there is something that we are not comfortable entertaining That would be good to know from the users from the stakeholders and so.

883
02:42:55.680 --> 02:42:57.600
Amanda Kohler: You know, certainly in your written comments.

884
02:42:59.550 --> 02:43:01.800
Amanda Kohler: This would be a good issue to discuss.

885
02:43:26.910 --> 02:43:27.060
well.

886
02:43:37.530 --> 02:43:41.730
Tess Fields: Okay Thank you everyone who has given us feedback.

887
02:43:42.870 --> 02:43:44.490
Tess Fields: Does anyone else have.

888
02:43:47.340 --> 02:43:51.420
Tess Fields: remaining questions or comments that they would like for us.

889
02:43:52.710 --> 02:43:58.620
Tess Fields: And if not, we'll move on to our how to stay involved after this meeting slide.

890
02:44:08.400 --> 02:44:10.080
Tess Fields: hi David, I think you can take it away.

891
02:44:17.880 --> 02:44:29.730
Stephen Donnelly: Alright, thanks Tess alright, so this remind you that the Federal Register notice is open and available for public comment until December 30, 2021, so.

892
02:44:30.870 --> 02:44:31.320
Stephen Donnelly: Now as.

893
02:44:32.340 --> 02:44:39.690
Stephen Donnelly: we've kept us over for a while, because we want your feedback, we want your comments and we also have are supplementary materials.

894
02:44:40.560 --> 02:44:48.930
Stephen Donnelly: They will be available and regulations.gov under docket number 2021 dash 0608.

895
02:44:49.440 --> 02:44:58.080
Stephen Donnelly: It takes a few days for materials to go from us requesting the be posted the docket to when they actually get in the docket so there might be a lifetime.

896
02:44:58.410 --> 02:45:06.330
Stephen Donnelly: Especially as we get the meeting recording and we get the transcript uploaded but then we looked at having actual material was putting the.

897
02:45:06.990 --> 02:45:16.590
Stephen Donnelly: via the example json uploaded as soon as possible and just remind you that we're going to be using this information from today's public meeting to inform.

898
02:45:17.550 --> 02:45:34.200
Stephen Donnelly: options for consideration by the manifest Advisory Board, so you if you if you want to participate in that please stay tuned and stay in contact with the manifest and we will have information, other than we plan on having a meeting in 2022 and we do encourage you to.

899
02:45:35.550 --> 02:45:38.640
Stephen Donnelly: Stay can't stay in contact, we have our next slide with.

900
02:45:39.720 --> 02:45:40.020
Stephen Donnelly: me.

901
02:45:41.040 --> 02:45:41.550
Stephen Donnelly: not there yet.

902
02:45:43.110 --> 02:45:59.700
Stephen Donnelly: right here yeah perfect and we also have ways to stay, we have a low volume listservs for program updates and developers, we have our website that is updated a lot, especially our FAQs and we also have our github repository where we put all of our software development.

903
02:46:02.430 --> 02:46:18.330
Stephen Donnelly: materials, as well as what up top help desk and then we didn't talk about generator read registration or and user registration, but that is always on our mind, so if you are a generator and you are not registered or you know, a generator that registered.

904
02:46:19.530 --> 02:46:29.850
Stephen Donnelly: Please let them know we have information on our website if they get stuck we have a help desk that can help them find their site and request site manager access or whatever access they'd like so please.

905
02:46:30.540 --> 02:46:36.660
Stephen Donnelly: If you are a generator and you're not registered please register and let this what this.

906
02:46:37.620 --> 02:46:42.450
Stephen Donnelly: What the world know that the manifest program once generators and transports register so.

907
02:46:42.750 --> 02:46:55.260
Stephen Donnelly: We can get some more electronic manifesting get you out into the fold for a lot of other requests dumpling biennial report or updating your site ID form there's a lot of great stuff to do once you're inside of the application.

908
02:46:56.940 --> 02:47:03.930
Stephen Donnelly: Alright, so I want to say thank you all for attending members of the public guards generators and transporters or brokers overseeing facilities.

909
02:47:04.620 --> 02:47:12.300
Stephen Donnelly: Members of academia other stakeholders, for the EPA and states, and I want to give a big thank you to the EPA manifest team.

910
02:47:12.660 --> 02:47:21.240
Stephen Donnelly: Particularly for marshaling this and put this all together a big thanks to a medical or Thank you Amanda thanks to our new members of the team and, thanks to our.

911
02:47:21.540 --> 02:47:35.070
Stephen Donnelly: Our seasoned veterans of the team, and we will end this webinar and we will be in touch with you all very soon, we have another meeting next week and have a great day and a safe and.

912
02:47:36.330 --> 02:47:37.440
Stephen Donnelly: happy Wednesday.

