Please Note: This document is a guide to the discussions between the EPA and their stakeholders during the e-Manifest Virtual Public Meeting dated November 3, 2021.

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Stephen Donnelly: All right, good afternoon, everybody or morning depending on where you come from this is the second of our virtual public meetings on increasing adoption electronic manifests, I am the e-manifest program manager.

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Stephen Donnelly: Steve Donnelly and we are here to present and talk and listen about all the things electronic manifest so before I get this thing going just a little bit of kick off.

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Stephen Donnelly: activity is that we have a recording and transcription has started and you're going to be posting links to those.

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Stephen Donnelly: And the transcription in our docket we're going to make these both these meetings available, and any subsequent meetings will be made available so.

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Stephen Donnelly: These are all being recorded and transcribed for posterity so thank you all, we have a lot to cover today and kick things off, I would like to introduce our division director so nice hospital.

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Sonya Sasseville: Okay hi everybody and welcome to our e-Manifest virtual public meeting focused 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 widespread adoption of electronic manifests is how we will truly unleash the benefits of the manifesting.

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Sonya Sasseville: And maximizing cost savings and burden reduction, improving the quality of manifest data integrating with Biennial Report requirements and enhancing monitoring of hazardous waste shipments nationwide were at an exciting time for e-Manifest since launching a.

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Sonya Sasseville: we've worked together to lay the foundation of our program EPA also spent time by way of several e-Manifest advisory board meetings and other user feedback venues.

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Sonya Sasseville: Learning the needs and challenges of our stakeholders with respect to electronic manifesting and we're working to try to address them.

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Sonya Sasseville: In 2020 and in 2020 and with concurrence from the e-Manifest advisory board we update date of our policy with respect to electronic signatures for generators transporters.

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

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Sonya Sasseville: However, we know that that isn't enough electronic manifest still represent just about and of total manifest volume.

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Sonya Sasseville: In 2021 we committed to the e-Manifest Advisory Board to explore other potential solutions to increasing electronic manifest adoption online users, which brings us to today's public meeting.

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Sonya Sasseville: Our objective today is to get early input from you that we can use and defining options or potential future consideration by the e-Manifest Advisory Board.

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Sonya Sasseville: What you may hear today is by no means a type of formal proposal or concrete plans by the Agency, we are at the idea stage and your input will be very valuable in shaping where we go next.

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Sonya Sasseville: I also challenge you to keep an open mind and embrace change as it may relate to your own current practices and systems in moving toward electronic manifest.

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Sonya Sasseville: we've always taken pride in the fact that he manifested success is shared success among our users, online states and our VP at regional partners.

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Sonya Sasseville: And, among others, that use and derive value from the data, so I encourage us all to continue working together to make this next leap possible.

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Sonya Sasseville: So, with that I know that the e-Manifest team is ready to begin presenting and eager to listen and learn from our stakeholders, so 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, oh, thank you, thank you so yep, so, let's just go over what we're going to be doing today so.

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Stephen Donnelly: We just went through our welcome and our welcome and then we're going to go through the meeting objectives in the background we're going to go.

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Stephen Donnelly: Why we're here while why we're doing this and what we hope to get out of these meetings.

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Stephen Donnelly: are going to have a walkthrough of the current electronic manifest workflow we're going to have some time to.

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Stephen Donnelly: have some discussion with you in the audience and hopefully answer some questions and make some new ones for consideration we'll take a break and then we're going to have a another in depth discussion on the policy.

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Stephen Donnelly: On the policy side of electronic signatures and we're going to have a discussion and follow on that we then we're going to have as we close out the meeting we're going to.

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Stephen Donnelly: throw the ball to you and ask for other potential options and considerations and we have to make this a really substantive back and forth between those of you.

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Stephen Donnelly: attending and those of us in headquarters, we might not have the answers for you right away, but we want you guys know that.

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Stephen Donnelly: We are listening to you were considering all the things you say, and we really want more electronic manifesto as well, so I'm going to pass it over to a familiar face David Graham to go through some of the some of the ground rules and West.

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David Graham: All right, thank you Steve so I know everyone's eager to provide all the comments Fortunately, thanks to zoom.

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David Graham: you'll be unable to actually unmute yourself during the presentation portion of today's meeting.

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David Graham: However, during the designated discussion portions if you'd like to provide a public comment which, again we highly, highly encourage you to do so since.

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David Graham: it's the primary reason for being here, please use the raise hand button, so a little window will pop up if you've never seen before, and one of the manifest team members will ask you to unmute yourself and then you can come on.

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David Graham: Have a conversation.

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David Graham: But during the entire length of the presentation, please put any questions comments concerns in the Q and A box and we will try to get to those as soon as we can in a timely manner.

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David Graham: And may also address some of those questions, if they are thought provoking, during the discussion portions as well.

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David Graham: Please note that the proposed times are approximate the times that Steve just showed you a minute ago, so if you're looking at the agenda, going "oh that's.

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David Graham: that's really interesting I like to come back and see that, but you know what I read e-Manifests Act everyday over breakfast and I know everything forwards and backwards skip that" just be aware that those times are approximate we highly encourage you to stay tuned entire presentation.

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David Graham: Also, please note that this meeting is being recorded and the recording and the transcript will be posted in the public dockets.

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David Graham: And where you can also provide written comments until December 30 this year, so when providing that public comment and come on, let me unmute you please make sure your comments are germane to the topic at hand and family friendly.

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David Graham: So, I'm going to pass this back over to Steve to go over.

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David Graham: Meeting objectives background.

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Stephen Donnelly: Yes, all right meeting objectives and background, yes, we can go to the next slide, this is what we go yeah, so this is why we are here, so the hazardous waste electronic manifest establish connect the manifest act.

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Stephen Donnelly: Well, they want us to have electronic manifests and we want full electric electronic manifest because as Sony said earlier.

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Stephen Donnelly: This is the this is how we decrease burden for our users, and this is how we get high quality data that can be used for integrating into by no reporting.

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Stephen Donnelly: And this can only be achieved, your wide adoption of electronic manifests electronic manifest as you are well aware.

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Stephen Donnelly: Are the smallest slice of the pie when it comes to divvying up the electronic map that's these are less than 1% of the approximately 2 million manifests the EPA receives annually.

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Stephen Donnelly: And the pace of electronic adoption false far short of agency expectations.

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Stephen Donnelly: So, the problem that is our problem alright, so our objective here is to solicit our individual feedback and ideas on ways to increase adoption of electronic manifest now.

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Stephen Donnelly: we've done a lot of high-level work for a very long time, however, today we're going to be getting very technical so moving forward as a program.

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Stephen Donnelly: We would like everybody, including industry states, regions headquarters, the public to be aware of the technical requirements and the pilot the technical policy requirements of electronic signatures.

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Stephen Donnelly: Because we want to use the information we get here from the document or from our when we have exchanges with our users here with your ideas, we want to be able to use this information to develop further options for consideration in an advisory board meeting in.

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Stephen Donnelly: And also, we want this, we want another purpose of this meeting is to increase understanding and use of the current workflow.

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Stephen Donnelly: And how it can be used, building on our data plus scanned image submission so we're going to be doing some very services-based discussions, and we want to be, we want people to understand Okay, this is how electronic manifest can work in our current system.

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Excellent.

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Stephen Donnelly: And should be noted that all these materials and resources will be added to the public docket, and we will be accepting written comments until December 30, 2021, so.

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Stephen Donnelly: If you have a question or comment and you don't get into the chat box, please use the docket to put that information in there, we would like to hear from you.

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Stephen Donnelly: All right back to David.

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David Graham: All right, thank you so a couple of more housekeeping items please keep in mind that this is not a federal advisory committee act or FACA meeting.

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David Graham: Which just means we need to ensure that we operate within a few certain parameters, so FACA generally applies to groups that EPA establishes or utilizes in the interest of obtaining group advice, recommendations and we take our FACA responsibilities very seriously.

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David Graham: However, at the same time it's also appropriate for EPA to get input from outside individuals such as yourselves and entities using other mechanisms such as this meeting that we're having today.

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David Graham: So, what you really need to take away from that is please keep in mind that we're seeking individual input not collected advice.

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David Graham: So, for example, if an organization sends an individual to more than one of these meetings or if that same organization and send.

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David Graham: Multiple representatives to the same meeting you're still providing input from that one organization right, and while we welcome discussion, we ask that you direct all your comments towards EPA not towards each other.

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David Graham: So, during today's conversation I know that there's a lot of.

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David Graham: e-Manifest hot topics that you want to talk about, but we are going to steer the conversation away from things such as data quality, paper manifest concerns, waste determinations,

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David Graham: user fees and budgets, and the highly anticipated e-Manifest third rulemaking so today our public meeting is solely focused on the discussion of increasing the adoption of electronic manifests.

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David Graham: Thank you in advance for your help, making this a fruitful conversation and I'm going to hand it back over to Steve.

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Stephen Donnelly: Yes, yeah and to sort of round up that last slide if you do have any of those concerns there's a lot of ways, we have we'll have our monthly public webinars back up.

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Stephen Donnelly: Soon, we also have our user support call so there's a lot of ways to bring up that information alright so let's go into the issue background of electronic manifests and take a brief stroll down memory lane.

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Stephen Donnelly: Now there's a lot of there's a lot of pre-history to the manifests you know we launched in 2018 there was an x signed in 2012 there was public meetings will be making.

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Stephen Donnelly: All throughout the early the early aughts in the 2010s and then there was also this was sort of bad at around the 90s, however, for the purpose of this meeting, and you get to the point.

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Stephen Donnelly: Will this will start will begin in June of 2019 when we had the advisory board meeting increasing adoption of the medical system, this was focused on the e-Manifest system has been around for a year and we were not seeing electronic we were not seeing a lot of electronic manifests.

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Stephen Donnelly: And we went to the board to specifically asked for information and action we can take to enhance the adoption electronic manifest and in September of 2019 the Advisory Board responded and recommended that the angels recommend the AMC reconsider.

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Stephen Donnelly: User registration processes and also acid we consider change to eliminate the Cross media electronic reporting real chrome air signature requirements for transactions prior to facility receipts and, in general, reevaluate the signature requirements.

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Stephen Donnelly: Alright, so following that following the Boards recommendations we recommended, we recommend it back to them.

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Stephen Donnelly: Increasing officer we so the board recommended and.

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Stephen Donnelly: We recommend it, so the board had the recommendation April 2020 and we proposed additional methods.

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Stephen Donnelly: for increasing use of electronic manifest this is now 2020, and this is our virtual advisory board meeting in April.

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Stephen Donnelly: And we proposed reengineering electronic signatures regenerated and transporters This included a non-register user.

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Stephen Donnelly: A method This included a method where the users, one person per site would be registered.

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Stephen Donnelly: This is where everyone had to be registered and then there was also a fourth solution where we discussed chromium compliance each pass.

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Stephen Donnelly: out the outcome of that meeting was the board concurred with the removal of the chroma key requirements for generator transporter signatures, as well as the initial signature by the receiving facility.

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Stephen Donnelly: So, the board listen to our proposal and said they agreed with the program's proposal that if it's not a final upload to the e-Manifest system.

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Stephen Donnelly: From the designated facility or nor correction, this is not needed to be a chromatic by signature and the board also recommended that we continue to work to integrate the manifest with the industry systems.

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Stephen Donnelly: All right, so in October 2020.

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Stephen Donnelly: EPA responded to the board's recommendations we confirmed that Cromer requirements apply only to electronic signatures for receiving facilities when submitting the final signed manifest to the EPA or when a user submits a post with the correction.

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Stephen Donnelly: And chroma requirements will not apply to electronic manifest signatures for generators transporters or the initial signature at the receiving facility when.

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Stephen Donnelly: receiving facility side to acknowledge receipt of the hazardous waste, so when that waste ends up at the loading dock and someone from the receiving facility signs electronically to say yes, we have a waste.

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Stephen Donnelly: That is a non-chromatic signature and also confirming that we will work with our stakeholders to explore solutions that will lower barriers of entry for industry.

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Stephen Donnelly: And as part of that we are here today and also in December of 2020.

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Stephen Donnelly: EPA deployed, the new quick sign functionality, which allowed those aforementioned generators transporters in the initial individuals at the loading dock.

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Stephen Donnelly: to sign a manifest electronic manifest in a non without were without using the chrome error compliant signature was clicking a button that says quick SEC.

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Stephen Donnelly: Okay, here we are, and we're almost up to we're almost up to speed.

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Stephen Donnelly: And March 2021 EPA, we had an advisory board meeting for the board to advise the Agency on its proposed program priorities and user fees or the upcoming.

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Stephen Donnelly: fiscal year the cycle and a key priority of that was direct engagements to stakeholders to increase electronic manifests.

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Stephen Donnelly: And in addition to you know reviewing the user fees, the initial program priorities which.

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Stephen Donnelly: are focused.

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Stephen Donnelly: in toto.

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Stephen Donnelly: To increasing electronic adoption of the manifest.

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Stephen Donnelly: The Board recommended the Agency address the lack of industry adoption to integrate with the hazardous waste industries private manifesting system, so a system-to-system connection with the e-Manifest and.

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Stephen Donnelly: In 2021, In June, we concur with the advisory boards recommendations, and we're committed and committed began to holding public meetings in 2021 to discuss potential options for improving the use of electronic methods.

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Stephen Donnelly: Thank you, thank you very much, there is a and, if you would like to go.

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Stephen Donnelly: In deeper to the Advisory Board recommendations and the Agency responses, this is all on the EPA website, so we have everything there if you go to the Advisory Board section, we have links to the meeting materials and the docket and also the AMC response if you are.

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Stephen Donnelly: If you are really interested in that stuff, so, I will pass this off to the e-Manifest technical lead Scott Christian take away Scott.

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Scott Christian: Thank you Steve.

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Scott Christian: Please next slide.

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Scott Christian: So, welcome to the current electronic manifest workflow.

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Scott Christian: Today we're going to go over three different sections of the agenda we're going to talk about mostly our services, those of you have been attending our monthly webinars and our packet presentations seen the user interface version.

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Scott Christian: Now we're going to go into services and explain why a little bit then I'm going to walk you through.

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Scott Christian: How the manifests API's can be used with what trunk manifests going to give you a step-by-step example with examples of a fully electronic manifest workflow as well as the hybrid manifest workflow.

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Scott Christian: And then.

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Scott Christian: William Nicholas on our team took these examples and wrote using the Python programming language, a DEMO of this and he's going to take those examples and show him but it's going to go through go pretty quickly so that's why I'm going to take the time to  explain them.

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Scott Christian: But uh yeah that's that perfect expectations explanation for the section, so what this section is technical it's going to be a technical section.

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Scott Christian: Section.

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Scott Christian: More technical and most of our public meeting sections that we've done we've had technical sessions like this in the past, but they've been more focused narrowly focused so we're trying to show you how easy it is for your system to talk to you manifest and.

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Scott Christian: Spread that information out to as many people as possible.

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Scott Christian: If you don't understand this at, all that is fine we're recording this as Steve said.

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Scott Christian: have an IT person in your company or organization look at it and be able to react and to help you.

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Scott Christian: react to your public comments I'm like I said, we are going to be providing examples of each step William's code is all on our github site The examples are all on our github site and in the docket.

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Scott Christian: So, your staff can recreate the DEMO and maybe yourself, create or recreate the DEMO.

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Scott Christian: Please contact us with questions, so we have a slide contact us slide at the end of the presentation.

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Scott Christian: We want you to use that we want to ask questions we in our team we answer questions all the time.

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Scott Christian: especially this year when we migrated from male to all electronic forms getting image only image plus data paper at this, as well as an increase in electronic map.

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Scott Christian: As you said, modest increase but it's an increase so.

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Scott Christian: we've helped people with services if you ask questions, we will answer them and probably help most of the companies on the on the call with their services questions, so we look forward to continue doing that, please use the contact us we want everyone to see the questions that come in.

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Scott Christian: On the team.

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Scott Christian: So, another explanation I'm gonna go slow on the because at the end, like I said, where it's going to go fast, I've done a little go fast, but that's the point the transaction supposed to go fast.

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Scott Christian: And then we're trying to show you options this isn't the end all be all the way we did it it's a way of doing it.

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Scott Christian: we're just trying to show there's a lot of ways to use a web services.

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Scott Christian: Finally, the main reason we're doing this is because most of the stuff comes in system to system it's actually 81% of manifests that come into the system is.

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Scott Christian: Data plus Image.

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Scott Christian: So, we have a lot of information in the system.

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Scott Christian: and

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Scott Christian: That comes in the full emits a full data let's migrate this to manifest to electronic map.

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Scott Christian: And so, getting back to that for a second and I'm going to take the section to kind of explain to everybody, what our system-to-system infrastructure is.

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Scott Christian: and hopefully you'll learn from it, so what is a ReST API we use rest APIs first of all what's an API and API is an application programming interface basically the way systems talk to each other.

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Scott Christian: And then one system sends a request the other response.

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Scott Christian: that's kind of a key piece that will get to throughout this presentation, then rest API or Representational State Transfer application programming interface.

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Scott Christian: What does that mean other than a bunch of PhD computer science speak.

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Scott Christian: it's a representation of the data in its state when it was sent to the other application.

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Scott Christian: I like to use the Mona Lisa as an example.

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Scott Christian: Everybody on this call, has seen an image of the Mona Lisa they've seen a representation of them always whether they've seen it person or they've seen it on a website.

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Scott Christian: And that representation is in the state that it was in when it was viewed.

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Scott Christian: Now let's say the folks at the Louvre want to upgrade the Mona Lisa or do something to that will make it last another 500 years.  It's 500 years old and still looks good for thousand years.

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Scott Christian: So, they do something and then they release another set of images and now you've seen another image of that same.

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Scott Christian: picture.

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Scott Christian: let's take this to manifest, probably a more relatable topic than art history.

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Scott Christian: The generators electronic manifest they see that is one representation of the manifest.

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Scott Christian: Then.

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Scott Christian: They sign it, the transport season now they're seeing a slightly different representation, because there's a generator signature on it.

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Scott Christian: Now there's a second representation, and the transporter signs.  The TSDF sees that there's two signatures on the manifest and signs and now there's three representations of the same thing, but it's how each one saw the manifest.

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Scott Christian: And so that's a reason we use rest, this is how that data is stored and kept and how it's transferred between each user that sees it.

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Scott Christian: Also, these are wildly type widely used API's they conform to certain standards, and when you use things that are important set certain standards.

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Scott Christian: are more likely to be well understood by developers, both when it's pretty much how the Internet talks rest API.

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Scott Christian: you're probably using rest API is watching this presentation if we're using teams, I would say, you were using rest APIs to watch this presentation, but I haven't looked into zoom's code so I'm going to say probably.

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Scott Christian: And then it's also more tolerant to the ups and downs of system so rest does give us some flexibility.

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Scott Christian: Thank you.

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Scott Christian: And then, this image here is just kind of helped drive in the point.

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Scott Christian: API's they're basically a lot like user interfaces 10,000 feet you user provides username and password a system provides an API key and credentials, and login sessions or API sessions are created and then people can exchange they know their trusted they can exchange information.

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Scott Christian: amongst themselves based off their.

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Scott Christian: credentials.

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Scott Christian: let's go to the next slide so that's great that they can.

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Scott Christian: communicate using the rest API but how do they speak what language are they talking what or how are they speaking to each other, this is why we use json is JavaScript object notation.

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Scott Christian: And like so with rest it's basically a fancy title for tech text file with predictable format.

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Scott Christian: I'm sure many of you heard of xml been around.

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Scott Christian: very similar it's you've got a text file with the predictable format.

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Scott Christian: The nice thing about json much more lightweight.

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Scott Christian: And we use it so when your system sends a request.

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Scott Christian: We respond in the same way with the same key.

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Scott Christian: information that you would request based off of a thing we call a schema, so how json is structured it's about it's a key value pair the key.

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Scott Christian: Is what this information generally is, and the value is what you're sending at that time, so we have an example here printed DOT information and then NA1993 waste diesel fuel.

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Scott Christian: Has a hazard Class three Packing group three.

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Scott Christian: So, the key printed DOT information it's on every hazardous waste line.

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Scott Christian: There is, but the value is going to be different, on the same manifest evaluate the different.

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Scott Christian: And there's a colon to separate the words as well.

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Scott Christian: So that's that now we're going to look at it, an example, this kind of mapped out the next slide.

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Scott Christian: Please, so we look here, this is a json.

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Scott Christian: we'll call it a file, but right there and then at the bottom, you see them.

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Scott Christian: waste line a waste line typical line one waste line printed from our system.

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Scott Christian: And DOT Hazardous is true.

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Scott Christian: If you look up their scopes goes down to 9a and you have X marked off its hazardous material then print DOT information, the same example from the previous slide and it's right there in 9b.

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Scott Christian: You have that there now as we look through.

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Scott Christian: A you have your number of containers type total quantity and.

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Scott Christian: Your unit of weight of volume, as well as the least code and those all mapped out now nice things we do is we have description, so if you were to retrieve this manifest.

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Scott Christian: you'd be able to see all the DM means battle drums barrels kegs chances are your system already knows that, but we have it in there, so for humans reading this json they have an easier time doing it or D001 they might not have all that stuff memorized so oh it's ignitable waste.

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Scott Christian: Depending on who's looking at.

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So, you can see, and.

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Scott Christian: perfect.

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Scott Christian: Now.

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Scott Christian: it's great I've just explained, all that, but why would you use API's. David Graham who spoke earlier summed it up great reason you use API's for the same reason you didn't nail gun instead of a hammer.

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Scott Christian: a hammer, you can build a house with a hammer and nail people done it for centuries, but it's a lot easier and it provides things in a more.

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Scott Christian: Reliable and repeatable format for a way of doing things so it helps take user error, out of the situation.

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Scott Christian: yeah, everybody here has ever used hammer nails probably smash their thumb you don't do that with a Nail gun.

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Scott Christian: So, you can take that either air out in a way, you can also help improve your compliance you by using API's and system, the system to kind of repeat those tasks that are repeatable.

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Scott Christian: And also have your insurances So if you look at our schemas there are.

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Scott Christian: Some basic insurance is on making sure that data is correct, but.

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Scott Christian: We also have business rules in the system as well, so the nice thing is using the API is.

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Scott Christian: You have some flexibility using your own programs and systems and adapting to this, so you can take a step out of the whole process rather than having to fill out paper forms.

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Scott Christian: So, and you know people we do recognize people have more patience with a paper form than they do with an electronic interface.

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Scott Christian: But.

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Scott Christian: They want once implemented those but try forms can work.

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Scott Christian: Very well.

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Scott Christian: So.

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Scott Christian: What and Why is he manifest using json well.

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Scott Christian: Like I said before, it's the same reason rest APIs are widely adopted standards more people can understand it.

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Scott Christian: How to use it more folks can.

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Scott Christian: be there to develop and there's a lot of tools available to support you and your developer. Nearly every tool set available can interact with ReST API's and JSON.

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Scott Christian: you're going to see a DEMO written by William on our staff, it was written in Python he manifests is written in Java David Graham he wrote some stuff using JavaScript.

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Scott Christian: Seen some commercial off the shelf products, a homebrew.

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Scott Christian: stuff that people use so.

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Scott Christian: chances are if there's a tool set out there, it can use API's even excel.

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Scott Christian: can use API's and word, as I was recently reminded.

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Stephen Donnelly: yeah, we build a manifest scalability manifest to be as neutral as possible that's why we go so far as you know, with the services and the data structures, because we know you have your systems.

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Stephen Donnelly: We have our system, so you can call it whatever you want, in your system, but if you're sending up do T hazardous.

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Stephen Donnelly: it's you're just going to send them something and you say, whatever your system says God has, as long as you send that marker up to our system and said.

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Stephen Donnelly: we're telling you manifest is do T hair, is it is this is the structure, they want this is what they want in that field we're good where is.

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Stephen Donnelly: Your is, we want to be as.

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Stephen Donnelly: easy as possible.

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Scott Christian: Perfect thanks day and then so now we're getting to the second phase of.

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Scott Christian: Our agenda, which is the workflows and we're going to do a fully electronic and go through it fully trying to go through a background of the shipment what the shipment basically is and then go through the.

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Scott Christian: process, step by step, and then we're going to go over we're going to do the same thing with the hybrid.

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Scott Christian: So just one sheet all see that goes this this next slide.

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Scott Christian: So, the full electronic background of the shipment.

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Scott Christian: In this example, a Tsdf company is arranging the shipment for a generator that can use fully electronic manifests.

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Scott Christian: The generator recently submitted a notification for the quadrennial sqG renotification and the Tsdf needs to update their systems information regarding this customer.

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Scott Christian: Now one little caveat So yes, this is a public service announcement to use our services to update your data, because a lot of sq geez have re notified.

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Scott Christian: Of the system does have I'll get into that when we go to the save a tool that will allow you to use them use record for data straight without you needing to.

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Scott Christian: upload the information, but in this case the Tsdf likes to upload the information from their system, and that is something that they can do.

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Scott Christian: And in this exercise will also update a waistline and take a manifester receipts, so this is, you know what has been described as kind of the typical shipment.

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Scott Christian: The driver shows up and change needs to be made to the manifest you can do that, via services and then move us along.

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Scott Christian: let's get So the first thing and going back several slides authentication out of the key to this.

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Scott Christian: To everything it tells us what you your user can do and what it cannot do.

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Scott Christian: and make sure you are so the authentication calls a simple call you'll see down here in the examples it's a request get.

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send them.

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Scott Christian: That was my water that almost spilled, sorry for all you have to hear that you send that URL with the API key and API key 

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Scott Christian:  as another public service never shares your API key it's just like a username and password you shouldn't share it.

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Scott Christian: But this API key.

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Scott Christian: Is there a substitute those send it off, you get back a token and an expiration 20 minutes later the expiration that we use which will get back to open for the next 20 minutes use that token, for all your all your calls.

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Scott Christian: And then we show you the Python function that blame wrote you man off is the function and where you can get it on github.

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Look at.

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Scott Christian: Finding a generator so with the public service announcement, we do have a site search and we released this rather recently within the past year.

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Scott Christian: And we want folks to use it, because it gives you a chance of getting the best information about your sites and ensuring that sites easy manifest because if you put a needle or C suite and they actually have an ID.

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Scott Christian: they're not going to see that manifest until that manifest is corrected so it's important to make sure your data is up to date, and we have the site search.

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Scott Christian: API.

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Scott Christian: And what it does is you send criteria that may make So if you have the ID and send.

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Scott Christian: A site id with the site search or one of our other site services and get information back about that site, whether it exists the details about that site, but you can also send the site search up and let's say you wanted to know all the CVSs in DC.

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Scott Christian: You can do that you would get back a lot of pages of results, you can cycle through, and the response is what you would get back and shows you details but CBS and Washington DC area.

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Scott Christian: William's function Python site search, if you look in the looking that.

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Scott Christian: Python file you'll be able to see it and see how he built that and then you can test out with those examples.

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Stephen Donnelly: Yes, really answer updating that stuff every day, every single day, those that site information is getting updated so.

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Scott Christian: You know.

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Stephen Donnelly: As soon as they submit it, they click enter on a submission to update or create a new site that is available to you for you to start off so yeah.

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Scott Christian: I'm willing to bet that while I've been speaking several sites have been up there.

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Scott Christian: So, the.

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Scott Christian: To create a fully electronic manifest safe so they're going to go through they know that the generator is fully electronic.

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Scott Christian: they're sending up that new site information that they pulled down from RCRA info in there, they didn't necessarily have to do that, they can just send the ID and the generators site and mailing address will be populated if it is in the database.

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Scott Christian: And you can use that so that way what you're sending up is what matches RCRA Info.

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Scott Christian: 

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Scott Christian: They can you send the manifest up, and the response, and the response back is the manifest tracking number that this manifest will have throughout and will be used on every subsequent call to manifest in relationship to this manifest.

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Scott Christian: So.

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Scott Christian: Now that this manifest has been created that the  dispatcher driver to the generators.

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Scott Christian: Please go to the next.

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Scott Christian: If they dispatch the driver to the generator and the driver is loading the.

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Scott Christian: drums on to their vehicle.

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Scott Christian: And they noticed couple drums can't go on.

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Scott Christian: and those drums are not ready to be shipped or they're not labeled properly, so we're not going to take these two this time, we'll come back and get it on our next scheduled shipment.

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Scott Christian: And so, the transporter in this case you have it as an example, using their own phone.

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Scott Christian: And an APP within their phone.

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Scott Christian: They make an update on their device they send that update with that manifest tracking number that was previously begun, and they get a confirmation that the update has been made, again we have the Python code for how you can do an update.

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Scott Christian: So, now that everything's ready this manifest is ready to go packed on the truck the.

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Scott Christian: transporter than says all right, the generator needs to sign, so they send a request, we have a user interface a link service and this user can be used for signatures and needs to get to the dashboard to get to the bulk sign page.

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Scott Christian: It can be used to get to a manifest and read only be used to get the manifest and the ability to sign it as well, in this case we're doing is just sign it.

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Scott Christian: And they send the request for info sends it back to the transporters phone because that's who requested the generator could have done it themselves as well.

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Scott Christian: And then the transporter out of band, out of the system  emails or texts, the link which came back in that response to the generator.

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Scott Christian: And then the generator could simply click on the link logs into RCRA info and goes to the quick sign for taking right to the signature page to click sign.

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Scott Christian: You will see this very fast quickly in Williams DEMO but.

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Scott Christian: There you have it now; we go to the transport us to do the same thing.

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Scott Christian: So, they click you I link service.

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Scott Christian: So, they can sign in their in their system they see the login to record info they click quick sign and finally.

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Scott Christian: 

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Scott Christian: Now go to the next slide and they need to get the printed manifest for the truck and, of course, we have a service for that, too, and the transporters phone calls it up.

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Scott Christian: Whether the unbeknownst to us or not calls it gets that image back and the transporter then just needs to send it to a printer whether they have not as remember may remember these electronic methods can be done on an eight and a half piece of paper in 8 half by 11 pieces of paper.

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Scott Christian: 

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Scott Christian: You don't need an impact printer or a dot matrix printer for it just need a printer little handheld printer, or the generator printed out for you, but the one sheet of paper goes in the truck and the TSDFs on their way they drive on the highway get to the TSDF.

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Scott Christian: And then the Tsdf user uses the UI link service in their application or they just login to the system.

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Scott Christian: And they send the request, and they get the link for that individual sign, so they can sign for receipt we're only showing quick sign in these examples today.  hopefully you have seen the full CROMERR sign before.

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Scott Christian: But this is to show you can quick sign for initial receipt a the Tsdf and then do a full sign later.

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Scott Christian: Next, we'll have hybrid scenario.  Scenario two is the same exact thing as scenario one except.

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Scott Christian: None of the generator's, registered signers are not on a site at the time shipment another individual that's trained with under.

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Scott Christian: Duty transportation title 49 training requirements is on site and can sign as a generator.

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Scott Christian: This is why we recommend people when they're doing their training, they.

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Scott Christian: They register for he manifests would cut down on this, but it's a situation Somebody needs to sign and.

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Scott Christian: That wasn't available on this date, but we have the hybrid option to protect that, as well as for sites that aren't registered yet.

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Scott Christian: And then in this exercise we.

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Scott Christian: will change the manifest to a hybrid make an update and take it through two to the TSDF.

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Scott Christian: The next slide.

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Scott Christian: The electronic manifest, this is the same exact thing we did before same exact manifesting.

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Scott Christian: And they sent the manifest that get back to manifest tracking numbers, the response.

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Scott Christian: 
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Scott Christian: So, when they came to the.

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Scott Christian: transporter comes to the site they notice person isn't there.

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Scott Christian: So, they have to make an update like they did before it's the same if you notice the same update call.

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Scott Christian: William made so you'll see that later same function like, I said it's repeatable reliable and, but this time instead of updating a waste line they're updating it from electronic to try Memphis to.

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Scott Christian: The nice thing is the generator was prepared, in this case, so they already have the printed piece of paper that they need to sign on paper per the hybrid.

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Scott Christian: Regulations they don't need to open upload that piece of paper they keep that on site, I believe, three years for the regulations, whatever the regulations say for record keeping requirements for hybrid manifests.

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Scott Christian: And they keep that piece of paper, but they have pre- printed because they knew the registered signers will not be off that day, so they wanted to save some time that's already there.

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Scott Christian: So, now that the manifest been update the UI link service is there, they.

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Scott Christian: transporter sense up the log in the system, the request, just like last time.

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Scott Christian: To get updates.

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Scott Christian: same exact things last time to send it to a printer with that.

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Scott Christian: generators.

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Scott Christian: printed name that was also sent when they sent it to change it to a hybrid.

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Scott Christian: On the manifest as well as the quick signing the transporter and the transporters on their way so see this repeatable process going much quicker and then use the UI link service.

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Scott Christian: So, in this case we're giving the same UI link service we're trying to show the flexibility of unique user interface link service this one goes to the bulk sign page, so the TSDFs computer they send it up and then they're taken to the bulk sign like sign multiple quick sign manifests.

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Scott Christian: So, they don't have to do just one, at a time, if you know we got a question last week, where a site was if I'm the transporter can I use the box answer, and the answer is yes, so the if the second transport is taking a waste that has 50 manifests on it.

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Scott Christian: The driver doesn't have to sit there and sign each one individually, they can quick sign off.

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Scott Christian: there's definitely some power here now with this, I am going to hand over the MIC to William Nicholas to go over the DEMO and thank you all very much for your time today.

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William Nicholas: Thanks Scott.

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William Nicholas: So, what you're about to see is a video, and while Scott correctly notes that this will go a little bit quicker it's still going to be significantly slower than if we.

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William Nicholas: were doing this live with a computer all the steps that you're going to see will have explanations and the advantage of using a tool, like our services is that this can all happen lightning fast in the background once you've set up a process using your computer code.

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William Nicholas: As noted the DEMO and the associated json files will be on our website and the Federal Register docket. Couple of notes: the runtime is about 16 minutes.

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William Nicholas: The audio on this is a little quiet, so I encourage you to turn up your speakers and I'll put a note in the chat when we're wrapping up to remind you, to turn it back down so we don't blow out your eardrums we're talking to you later.

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William Nicholas: And the final thing I'll remind you, is if you're having trouble seeing the video. I'll encourage you to go up to the top right corner of your screen there's a view button in the zoom tab.

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William Nicholas: And you can play with some options there in case you have some issues with visibility with that I'm going to turn it over to Steve and encouraged him to roll the video thanks.

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Hello everyone, welcome to the he manifests 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 TSETFs 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 and 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 foil 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 conduct.

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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 if 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 that 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 2021 here in our own tenant 22202.

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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 site 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 in 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 recur 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 transporter could sign this 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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Sunday 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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There we go I'm taking back to.

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The screen, where I can see that I have just.

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sent 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 tonight.

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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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William's application generated from me and 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 this point, I can go through, I can specify the information generator information, the generator ids correct transporter information all the stuff.

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

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confirm that all the information is again correct.

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Now that manifest has been signed by the generator transporter and it doesn't need to receive facility.

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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 manifest 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 json 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 there's 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.

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

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and

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

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And I can now go and click sign see the transporting knowledge we receive materials quick sign again and I'm taking back to the dashboard.

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And then I drive away and.

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And it backed away.

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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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I can go ahead and run that get attachments command and you'll see here and my file structure that I've gotten that 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.

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In this case, I've just seen that Scott has signed up.

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01:04:38.610 --> 01:04:54.540
So excellent now it's ready to be signed once it gets to the TSDF and so I'll generate a link specifically for are receiving facility and I'll send that over to David, who is serving as our receiving facility.

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01:04:57.270 --> 01:05:05.820
All right, thank you, William again so for purposes of this demonstration I'm already logged in as our Tsdf.

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01:05:06.960 --> 01:05:11.640
And then I click on that link that Williams DEMO application 70.

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01:05:13.980 --> 01:05:17.070
pulls up a new tab again I'm already signed in.

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I can see, I have the option to chrome air 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 a moment and I click both like dollar.

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filter or just sign manifest that I want to sign.

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01:05:40.650 --> 01:05:46.320
Also review if you'd like but for purposes of the day we're just going to go ahead and click sign both these manifests.

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Again, confirmed information is correct.

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01:05:52.380 --> 01:05:54.960
And our electronic manifest now complete.

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01:05:57.390 --> 01:06:09.000
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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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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01:06:40.140 --> 01:06:54.360
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@github.com slash us EPA slash you manifest.

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Thank you.

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Stephen Donnelly: All right, what a video Thank you.

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William Nicholas: So, thanks everyone for watching the DEMO as a reminder, this is sample scenario, this is simplified one transporter, and everything takes a little bit longer because we're explaining.

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William Nicholas: When you're implementing this in your own system, this is, you know more or less instantaneous. The power that these.

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William Nicholas: APIs offer you is their flexibility, whether you want to use Python any number of other programming languages or extend them as part of tools you already have.

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William Nicholas: You know, regardless of your systems and your processes, you can adapt these to achieve your goals take advantage of the cost savings, the data quality improvements and the overall efficiency of electronic manifesting.

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William Nicholas: One note the receiving facility will still need to finalize the manifests at the end to be compliant but the UI link service you saw provides an API to help with them.

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William Nicholas: And while the generator signs the hybrid manifest on paper it's the electronic representation of that signature that's uploaded to the system via the API.

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William Nicholas: As I note in the video if you've got questions about this from a technical perspective you'd like to dig in and understand how it applies to your own systems.

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William Nicholas: You know I encourage you to reach out to us to check out our github to join our developer's listserv and to attend our meetings in the meantime I'm going to hand it over to my colleague tests, who will open it up to Q and A and some discussion points that we'd like to answer, thank you.

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Stephen Donnelly: that's real quick William I.

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Stephen Donnelly: would like to point out, and he said this, and it gives you bears repeating that you can send a link to someone with.

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Stephen Donnelly: hundreds if not thousands of manifests that need to be signed, using the chrome air compliance, it gives you this could go for your final submission to the EPA or, as well as correction so.

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Stephen Donnelly: Is that just quick sign, you can use these links, for, if you have somebody in your organization and needs to that you designate assigned to manifest you can create that badge for them and send it right to the music.

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Stephen Donnelly: What we live in the future to bass.

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Tess Fields: Thanks Steve.

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Tess Fields: So now we have some time set aside to discuss some questions that we would like to pose to you and hear your feedback, as well as answer questions that you all have put in the chat.

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Tess Fields: But before I read these discussion questions, I see Angel you have had your hand raised for a little while so if you'd like to unmute yourself and.

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Tess Fields: chime in please feel free now.

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Angel: Can you hear me.

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01:09:57.270 --> 01:10:02.010
Angel: Yes, okay, so if I'm understanding this correctly.

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Angel: Once the transporter leaves the generator site and.

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Angel: delivers.

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Angel: The shipment to the designated facility.

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Angel: I can get an electronic copy of the designated facilities signed copy to download and keep in my files.

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Scott Christian: Tess, you want me to answer this one.

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Tess Fields: yeah, correct.

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Scott Christian: So, you can get the.

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01:10:40.710 --> 01:10:44.160
Scott Christian: copy so record for each signature.

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Angel: Okay, and then for the generator copies still have to, we still have to sign a copy of that the transporter has Is that correct.

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01:10:52.890 --> 01:11:07.470
Scott Christian: assume that depends on the situation so in the hybrid Yes, they stopped the sign that piece of paper copy but for the fully electronic they're designing it like I like I tried to show electronically.

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Angel: uh huh so.

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Scott Christian: The record keeping requirement is the system.

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Angel: OK, so the transporter will have an electronic system that I can just tune.

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Angel: Like you, when you sign your signature on a credit card.

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Angel: Debt machine.

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Scott Christian: All right, yeah, I think I guess you mean like when you're signing at the at the grocery store on the little pad yes so, it's similar to that.

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Angel: Okay.

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01:11:41.430 --> 01:11:47.910
Scott Christian: good example so be electronic representation that quick sign representation is in the system.

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Scott Christian: and not on paper for full electronic.

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Angel: Okay, so then well, I still have to wait to get an electronic copy of the generators portion of that manifest or will I, will she be able to print one for me.

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01:12:07.170 --> 01:12:17.130
Scott Christian: I'm the generator would be so if you're the transporter and you need the copy for the truck anyone with access to them manifest can print out that car.

456
01:12:18.270 --> 01:12:19.560
Angel: Okay, as the generator.

457
01:12:20.760 --> 01:12:24.900
Angel: If it's fully electronic how do I get my copy of the generators.

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01:12:26.820 --> 01:12:29.490
Angel: Which is the final of the Multi form.

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01:12:31.260 --> 01:12:35.670
Scott Christian: You login the there's no more mail and with the whole electronic manifest there's no mailing.

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01:12:38.220 --> 01:12:38.580
Angel: Okay.

461
01:12:38.640 --> 01:12:42.000
Scott Christian: So, you just log in in that the system is the record keeping requirement.

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01:12:42.840 --> 01:12:47.970
Scott Christian: Okay I'll let test and Bryan on the exact language on that, but the system.

463
01:12:48.030 --> 01:12:59.280
Bryan Groce: Okay, so Scott, this is Bryan so for the hybrid manifest the generator is not registered or is unregistered for manifest access so.

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01:12:59.700 --> 01:13:17.370
Bryan Groce: Although the manifests originate in the system as electronic manifests that manifest is printed out for the generator by the initial transporter generator signs that manifest the printed copy and keeps that copy, as well as the transporter, generator keeps that copy.

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Bryan Groce: For its records.

466
01:13:20.760 --> 01:13:27.990
Bryan Groce: The other workflow the electronic aspect of it, the initial transporter and subsequent transporters and the receiving facilities.

467
01:13:28.440 --> 01:13:43.710
Bryan Groce: Their copy of record will be that final signed copy by the transporter I mean I'm sorry by the receiving facility so which would be in the system so unless a generator has access to the system, they must keep a hard copy of that manifest on record.

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01:13:45.000 --> 01:13:45.540	
Bryan Groce: on file.

469
01:13:46.620 --> 01:13:48.750
Angel: Okay, and as the electronic.

470
01:13:50.730 --> 01:13:54.810
Angel: system available for the generator to register to use or is.

471
01:13:55.410 --> 01:13:57.750
Angel: It it's available to any.

472
01:13:58.650 --> 01:14:13.680
Bryan Groce: company or site that wants to participate in electronic manifest or perhaps that wants to have access or use the system for its for record purposes if they register they have that opportunity.

473
01:14:14.700 --> 01:14:15.030
Angel: Okay.

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01:14:16.770 --> 01:14:20.460
Angel: That clears up my questions I like it, I like system.

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01:14:21.240 --> 01:14:30.120
Stephen Donnelly: And we have a for registration in order to get ahead of ourselves, we have a help desk, and we have a lot of materials on the website I'll throw that into the chat as well, so for people to see.

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01:14:31.170 --> 01:14:33.840
Angel: Excellent Thank you very much, this is great.

477
01:14:34.020 --> 01:14:34.410
Tess Fields: I love it.

478
01:14:37.860 --> 01:14:53.340
Tess Fields: um so David if you could go to the next slide I will read through these questions and we'll take comments on them or other related topics, so if you'd like to speak, please click the raised hand button and I'll unmute you in the order in which your hands are raised.

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01:14:55.170 --> 01:15:06.300
Tess Fields: So, the first question is what improved understanding of the existing electronic manifest workflow similar to today's presentation encourage users to adopt electronic manifests.

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01:15:07.350 --> 01:15:15.090
Tess Fields: And what types of assistance from EPA, for example, would be needed for users to adopt the existing electronic manifest process.

481
01:15:17.130 --> 01:15:22.860
Tess Fields: So, if you have thoughts on either of these questions or.

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01:15:25.500 --> 01:15:33.660
Tess Fields: The e-manifest system or process in general, please feel free to raise your hand and give us some feedback.

483
01:15:36.360 --> 01:15:37.380
Tess Fields: Yes, Robert.

484
01:15:42.660 --> 01:15:43.290
Robert Fronczak: Can you hear me.

485
01:15:43.650 --> 01:15:51.570
Robert Fronczak: Yes, okay um yeah, I mean what I saw it looks pretty simple. I've talked to my members and.

486
01:15:52.800 --> 01:16:05.340
Robert Fronczak: Which are the railroads and it, you know what they would like is a system that notifies them when a manifest is you know coming to them for signature.

487
01:16:05.880 --> 01:16:19.770
Robert Fronczak: In other words, you know, a shipment is coming to them for pickup it do you have to be in into the email for system to get that notice or can that be sent to an email address.

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01:16:22.890 --> 01:16:26.400
Tess Fields: Thank you for your question, Steve or Scott, do you want to.

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01:16:27.600 --> 01:16:27.870
Tess Fields: Address?

490
01:16:31.980 --> 01:16:36.840
Scott Christian: To a user would has to be in the system in order to.

491
01:16:38.910 --> 01:16:41.160
Scott Christian: With the credentials in order to see a manifest.

492
01:16:42.390 --> 01:16:43.170
Scott Christian: So.

493
01:16:46.020 --> 01:16:50.070
Scott Christian: A user would have to have access to been to several sites.

494
01:16:52.440 --> 01:16:53.820
Scott Christian: In order to do that so.

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01:16:56.340 --> 01:17:00.570
Tess Fields: And I think this question also is about like notification of when you.

496
01:17:01.530 --> 01:17:04.500
Scott Christian: need to sign soon so you're.

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01:17:04.530 --> 01:17:16.020
Robert Fronczak: not always they don't want to have to go in and check the system to see if they've got a manifest waiting for them, they want some sort of notice from you that there's one they're ready for them right.

498
01:17:16.110 --> 01:17:18.060
Scott Christian: And one thing that.

499
01:17:20.580 --> 01:17:28.770
Scott Christian: I know some of the sites that use the manifest have done is they set up a poll in their system to.

500
01:17:29.880 --> 01:17:40.380
Scott Christian: ask us if so there's that there's a one of the services we did not show is a manifest search service.

501
01:17:41.490 --> 01:17:49.500
Scott Christian: And what those services been used for is to pull email, and the first to see if there's any manifest waiting for them.

502
01:17:51.120 --> 01:17:58.500
Scott Christian: So, they on the hour on the half hour send hey, are there any manifest since the last time I call.

503
01:18:00.030 --> 01:18:07.320
Scott Christian: No, it's also actually our other systems to interact with the manifests as well with.

504
01:18:09.090 --> 01:18:21.750
Robert Fronczak: That and that sounds reasonable, but would it be possible for us to set up a webinar with you guys to go over this so that you know they can see this and get their questions answered.

505
01:18:22.800 --> 01:18:30.840
Scott Christian: Actually, yes, it's kind of funny we're in preparation, we had a hunch that you had your job.

506
01:18:32.580 --> 01:18:33.480
Scott Christian: So, a.

507
01:18:34.470 --> 01:18:39.810
Stephen Donnelly: ar is we've been around that's that type of the history of the manifest you guys have been around for a very long time.

508
01:18:40.140 --> 01:18:41.160
Robert Fronczak: 20 years.

509
01:18:42.390 --> 01:18:43.260
Scott Christian: So.

510
01:18:44.280 --> 01:18:48.240
Scott Christian: It would, it would be good to see and hear and because.

511
01:18:50.250 --> 01:18:51.990
Scott Christian: The json and.

512
01:18:53.100 --> 01:19:01.140
Scott Christian: edi won't talk to each other, but you know, like you know my first job out of college, I had to translate API to.

513
01:19:02.430 --> 01:19:06.540
Scott Christian: Something else to make it so that my database, we talked to it.

514
01:19:08.520 --> 01:19:15.360
Scott Christian: So, we get it, but there, you know that those interfaces kind of happen to happen, and how can that happen.

515
01:19:17.460 --> 01:19:20.580
Scott Christian: So, contact us okay let's do.

516
01:19:21.330 --> 01:19:25.230
Stephen Donnelly: From what I'm hearing, too, is that.

517
01:19:25.260 --> 01:19:27.780
Stephen Donnelly: What specially the second question is.

518
01:19:29.310 --> 01:19:37.290
Stephen Donnelly: Users that we heard this in the first session, where you can now is people would like the manifest system to tell them there there's a manifest themselves.

519
01:19:38.880 --> 01:19:40.470
Stephen Donnelly: They want you know they want.

520
01:19:42.270 --> 01:19:49.140
Stephen Donnelly: They want hey here's your manifest xyz here it is they want the system to copy that, so I've heard that a few times.

521
01:19:57.240 --> 01:20:01.830
Robert Fronczak: So, so should I just talked to you Steven offline to try to set something up okay.

522
01:20:01.890 --> 01:20:15.420
Stephen Donnelly: Well, if you have, if you have any more, if you have any more input or questions, please share that but also, you will have a we have a contact us slide so yeah do not be awake scout saying don't don't hesitate to contact us with many any and all concerns.

523
01:20:15.750 --> 01:20:17.190
Robert Fronczak: No, I'll stay on the line.

524
01:20:20.730 --> 01:20:21.330
Tess Fields: hey Thank you.

525
01:20:28.200 --> 01:20:31.200
Tess Fields: Stacy, please, go ahead and unmute yourself.

526
01:20:33.060 --> 01:20:58.980
Stacy Sinclair: hi Thank you so much for the opportunity um I am working in a hybrid situation and by local area has said that we need, we need to go completely digital I'm trying to figure out how to do this on construction sites where our transporters don't have.

527
01:21:00.090 --> 01:21:12.690
Stacy Sinclair: Access to printers neither do our on-site workers and due to security and safety requirements, they cannot have access to tablets.

528
01:21:14.130 --> 01:21:22.380
Stacy Sinclair: So, we can't go full electronic, and we can't print for hybrid.

529
01:21:31.020 --> 01:21:33.030
Tess Fields: Scott or Bryan?

530
01:21:37.980 --> 01:21:41.340
Scott Christian: To Brian because of the whole timing of a signature.

531
01:21:43.080 --> 01:21:44.040
Scott Christian: There is a.

532
01:21:48.060 --> 01:21:49.800
Scott Christian: yeah, the whole timing of the signature.

533
01:21:50.880 --> 01:21:52.020
Scott Christian: Part of the conversation.

534
01:21:53.250 --> 01:22:06.030
Scott Christian: Because it is also has come up with like national security sites as well, where they get their devices back after a certain point, if they can go in, but they have to hand their devices over.

535
01:22:08.190 --> 01:22:12.930
Scott Christian: And then, then they can go and sign up at that point it's a but.

536
01:22:14.910 --> 01:22:19.140
Scott Christian: I know that, to a quote policy, I can quote the system, but not the policy terms.

537
01:22:20.160 --> 01:22:20.520
Scott Christian: Right.

538
01:22:20.880 --> 01:22:22.950
Bryan Groce: yeah, this is Brian edible.

539
01:22:23.040 --> 01:22:26.550
Bryan Groce: necessarily have answered this time I think one of the things that we are.

540
01:22:28.380 --> 01:22:29.580
Bryan Groce: hope to discuss today.

541
01:22:31.410 --> 01:22:40.470
Bryan Groce: Is in terms of what are legal, legal and valid signatures for electronic manifest purposes, so I just want to hold off and reserve any.

542
01:22:41.610 --> 01:22:47.670
Bryan Groce: questions you might have for that time but, at the very least, if we cannot answer that question today.

543
01:22:48.870 --> 01:22:55.860
Bryan Groce: Please submit your comments his issues comments and questions to the docket and we will address them at a later date.

544
01:22:57.180 --> 01:22:57.540
Thanks.

545
01:23:01.770 --> 01:23:03.540
Tess Fields: Thanks bye Thank you Stacey.

546
01:23:06.060 --> 01:23:07.980
Tess Fields: yeah, that's a good reminder by Brian.

547
01:23:09.180 --> 01:23:14.910
Tess Fields: Please submit your fleshed out comments your written comments into our public docket.

548
01:23:22.650 --> 01:23:32.550
Tess Fields: Many one else who would like to provide some feedback or ask questions and we'll have time at the end of our session today as well to.

549
01:23:33.180 --> 01:23:47.130
Tess Fields: ask questions and comment again so you can even think about it for a little while but uh I'll pass it over to Brian to answer some questions that have been posed in our Q&A box.

550
01:23:50.340 --> 01:23:57.060
Bryan Groce: Thanks to So yes, so we have received a lot of questions from the railroad industry regarding.

551
01:23:58.620 --> 01:24:11.070
Bryan Groce: Some strong desire to have discussions with us EPA regarding sort of the communication between their Idi I believe that's the electronic data interchange.

552
01:24:11.580 --> 01:24:34.860
Bryan Groce: And perhaps json or just our system in general, so I think there was an agreement to have perhaps having a webinar I don't so again, I strongly suggest that you submit your comments and your request to our docket, and we will address those at a later date there's also.

553
01:24:36.000 --> 01:24:40.320
Bryan Groce: Other questions, besides the road wins on.

554
01:24:42.330 --> 01:24:51.540
Bryan Groce: there's a question about is the driver required to register to quick sign are just Trent just transport company so at this time.

555
01:24:52.890 --> 01:25:12.090
Bryan Groce: The driver is required to register for he manifests us and signing up the using the quick sign the process, the registration process is not as rigorous as the registration process for the fully compliant premier signature.

556
01:25:15.120 --> 01:25:19.650
Bryan Groce: I believe in terms of quick sign; you can register as a preparer when you.

557
01:25:20.790 --> 01:25:24.660
Bryan Groce: In your county register as a preparer, you don't necessarily have to.

558
01:25:26.010 --> 01:25:41.430
Bryan Groce: develop the challenge questions and there's no I I believe there's no identification validation component, but I will defer to Steve or Scott on that so to answer your question, yes, you still must register, but the registration process is much simpler.

559
01:25:42.930 --> 01:25:44.250
Scott Christian: Bryan, you nailed it on that.

560
01:25:44.580 --> 01:25:48.030
Stephen Donnelly: One again this is sort of let throw this out there to everybody, one of the.

561
01:25:49.200 --> 01:25:57.870
Stephen Donnelly: One of the sort of ground rules of like federal system management security management is that going to be changing something or accessing a system.

562
01:25:58.290 --> 01:26:10.710
Stephen Donnelly: For the most part, you need to be registered so for all intensive purposes, if yeah someone a driver is going to be signing a manifest, then the system would.

563
01:26:11.190 --> 01:26:18.390
Stephen Donnelly: really like to know who that person signing the manager so like a lot of a lot of anonymous changes or non-registered changes to a system.

564
01:26:19.170 --> 01:26:34.950
Stephen Donnelly: I'm not gonna say impossible, but in terms of like you know Federal Security and system management, the way EPA and federal government likes it is that yeah, you're going to be sunny manifesto change can manifest or doing a to manifest the system wants you to have your own individual.

565
01:26:38.490 --> 01:26:42.690
Bryan Groce: Thanks Steve so yeah So there are a few other questions here.

566
01:26:44.460 --> 01:26:54.900
Bryan Groce: One question will this presentation be available, once this zoom meeting ends and, yes, the answer is yes, in fact, the presentation is already available.

567
01:26:55.710 --> 01:27:09.690
Bryan Groce: In our docket we recently held our first public meeting on October 27 and that presentation, along with the transcript is available, and we will post our.

568
01:27:11.070 --> 01:27:12.330
Bryan Groce: transcript to this meeting.

569
01:27:13.560 --> 01:27:25.800
Bryan Groce: Following the completion of this meeting, so let me correct myself so the presentation itself the slide presentation is available for this meeting and the previous one transcripts, however, will not be available.

570
01:27:27.120 --> 01:27:32.790
Bryan Groce: Until we post them in the system, into the FDMS system.

571
01:27:34.110 --> 01:27:35.730
Bryan Groce: And that will happen, following this meeting.

572
01:27:38.430 --> 01:27:39.750
Bryan Groce: there's another question.

573
01:27:41.820 --> 01:27:44.370
Bryan Groce: generators, the question is, do generators.

574
01:27:45.630 --> 01:27:48.000
Bryan Groce: Each only register in America info.

575
01:27:49.530 --> 01:27:56.070
Bryan Groce: Without the transporter being registered in the system so essentially, I guess this question is.

576
01:27:57.720 --> 01:28:03.990
Bryan Groce: Can the generator participate and use electronic manifest without the transporter participating.

577
01:28:05.940 --> 01:28:07.680
Bryan Groce: So really it.

578
01:28:08.730 --> 01:28:13.650
Bryan Groce: depends for fully electronic, if you want to use a fully electronic workflow.

579
01:28:16.050 --> 01:28:20.460
Bryan Groce: All parties involved on manifests or in the manifest ys.

580
01:28:22.110 --> 01:28:23.670
Bryan Groce: tracking have to be.

581
01:28:25.020 --> 01:28:27.780
Bryan Groce: registered in the system for access.

582
01:28:29.580 --> 01:28:36.450
Bryan Groce: However, in this way, so for the hybrid manifest as we mentioned, as mentioned previously, the generator does not need to be registered.

583
01:28:37.050 --> 01:28:45.420
Bryan Groce: However, the transporter and subsequent transporters, as well as the receiving facility must be registered in the system.

584
01:28:46.350 --> 01:28:52.860
Bryan Groce: So, it really depends on if you're a generator and you want to participate in in a fully electronic workflow.

585
01:28:53.340 --> 01:29:05.610
Bryan Groce: All parties involved with your shipment must be registered in the system for that, and if other parties other than generator want to participate in the electronic tracking workflow.

586
01:29:06.420 --> 01:29:16.290
Bryan Groce: They must be registered generator does not have to be but they have to provide that generated with a hardcopy printed copy of that electronic manifests for their record keeping purposes.

587
01:29:16.920 --> 01:29:24.030
Stephen Donnelly: And so quickly, I know that in the system, but the user interface with you, if you search for a site ID it'll tell you that.

588
01:29:24.510 --> 01:29:29.280
Stephen Donnelly: If that transporter site has a registered user, so you can participate in electronic manifests.

589
01:29:29.670 --> 01:29:41.820
Stephen Donnelly: And also, that same information is available in using services when you do a site search show the system knows that you want to know that hey does this transporter have electronic a person who could do a manifest or not.

590
01:29:49.140 --> 01:29:49.590
Bryan Groce: Thanks, see.

591
01:29:50.970 --> 01:29:53.220
Bryan Groce: It see there are questions here.

592
01:29:57.960 --> 01:30:00.540
Bryan Groce: yeah, I think, for the most part we've answered.

593
01:30:02.100 --> 01:30:06.120
Bryan Groce: The relevant questions again, there are a lot of questions regarding API.

594
01:30:08.280 --> 01:30:20.070
Bryan Groce: By the railroad industry and again if there if your question was not answered our issue was not addressed. Please submit your comments to our docket and we will address them at a later date.

595
01:30:22.620 --> 01:30:23.040
Thanks.

596
01:30:30.510 --> 01:30:30.750
Bryan Groce: So.

597
01:30:31.860 --> 01:30:35.850
Bryan Groce: Dave or Steve out turning over turn it over to you now.

598
01:30:39.180 --> 01:30:41.160
Stephen Donnelly: Is that right now um it's good question.

599
01:30:42.870 --> 01:30:44.550
Stephen Donnelly: So, Q and A we just did that.

600
01:30:53.340 --> 01:30:56.130
David Graham: So, do we have any other additional questions like to answer.

601
01:30:58.740 --> 01:31:00.720
Stephen Donnelly: It is, I didn't see it, we have a question.

602
01:31:02.130 --> 01:31:11.430
Stephen Donnelly: Are there API services to register a quick sign user so each person needs to register their register for their own individual account.

603
01:31:12.120 --> 01:31:25.110
Stephen Donnelly: And to use API services, you need the site manager's permission, and we have all that we have all that spelled out on our website, so we do have user registration information on the website throw it in there.

604
01:31:26.130 --> 01:31:29.010
Stephen Donnelly: about what to do and how to get the access to me.

605
01:31:46.890 --> 01:31:47.220
Great.

606
01:31:49.740 --> 01:31:54.720
Tess Fields: Well, if we don't have any other questions. I believe up next is a 10-minute break.

607
01:31:59.490 --> 01:32:10.320
Tess Fields: So, we will reconvene at 250 please go take the time to stretch your legs and we will reconvene for the policy discussion.

608
01:32:11.490 --> 01:32:15.180
Tess Fields: portion of our webinar so thank you.

609
01:45:20.820 --> 01:45:25.440
Amanda Kohler: Okay welcome back from break everyone, my name is Amanda Kohler.

610
01:45:26.970 --> 01:45:30.240
Amanda Kohler: And we are going to go into the second part of our meeting.

611
01:45:33.210 --> 01:45:43.110
Amanda Kohler: And I have okay sorry just didn't set so the first part of today's discussion focused on the current electronic manifest workflow as it exists.

612
01:45:43.410 --> 01:45:57.930
Amanda Kohler: In our manifest system, this second session we'll talk more about what could be particularly your respect to options that include users uploading electronic signatures to our manifest system so for this section we're going to.

613
01:45:58.710 --> 01:46:02.370
Amanda Kohler: Have a short introduction kind of explain where we are in terms of.

614
01:46:03.300 --> 01:46:11.340
Amanda Kohler: The planning process for these will talk about applicable statutory and regulatory requirements that would apply to any future scenario.

615
01:46:11.970 --> 01:46:18.360
Amanda Kohler: You know, particularly any scenario that we envision will you know must meet the manifest act requirements.

616
01:46:18.720 --> 01:46:25.800
Amanda Kohler: With respect to regulations, we are open to regulatory change where it makes sense, but any scenario that already fits within the existing regs.

617
01:46:26.430 --> 01:46:33.660
Amanda Kohler: Maybe prefer just because rulemaking takes time and so solutions that already fit within the regulations will be faster to implement.

618
01:46:34.440 --> 01:46:52.680
Amanda Kohler: And then, this after we talked about the Statute regs we're gonna go through some electronic manifest workflows so Steve and I will volley back and forth in terms of describing some options and then coming back in applying the statutory and regulatory framework to those options.

619
01:46:53.910 --> 01:47:04.980
Amanda Kohler: And then we'll finish with valid enforceable electronic signatures and that language valid enforceable is important because that's the language that's in our existing manifest regulations for definition electronic signature.

620
01:47:09.120 --> 01:47:18.060
Amanda Kohler: Okay, so setting the stage here our last advisory board meeting focused on program priorities and user fees for FY22/23.

621
01:47:19.380 --> 01:47:24.870
Amanda Kohler: Including our long standing and highest priority goal to increase adoption of electronic manifests so.

622
01:47:25.290 --> 01:47:32.370
Amanda Kohler: With respect to that the Advisory Board recommended to us that we you know we do the following we brought in the concept of a fully electronic manifest.

623
01:47:33.000 --> 01:47:39.900
Amanda Kohler: We continue the pursuit of regulatory change where it makes sense to do so, and we integrate the manifest with the hazardous waste industries.

624
01:47:40.170 --> 01:47:53.100
Amanda Kohler: Private manifesting systems and that's really to capitalize on a lot of the success that we've seen to date with the data plus image uploads where the majority of our manifests are coming in system-to-system connection like Scott mentioned earlier.

625
01:47:55.170 --> 01:47:59.550
Amanda Kohler: So, with that you know we committed to in our response, the Advisory Board to.

626
01:48:01.080 --> 01:48:12.870
Amanda Kohler: Consider, you know potential options for increasing electronic manifest including getting stakeholder input earlier on in our in our process so with that I did want to make sure that we have.

627
01:48:14.160 --> 01:48:19.770
Amanda Kohler: set the stage completely here, so I did want to reiterate, and you know somebody had mentioned this early in her talking points that.

628
01:48:20.760 --> 01:48:29.700
Amanda Kohler: These are early concepts that we're about to discuss, they have not been fully vetted internally in our agency, we are looking forward to getting input early on.

629
01:48:29.970 --> 01:48:40.710
Amanda Kohler: So that that will really help us determine what direction we move in in order to more robustly flush out an option that we would then formally propose to the Advisory Board so.

630
01:48:41.340 --> 01:48:49.260
Amanda Kohler: So, no final decisions, you know these are just early leanings, these are not formal proposals that would then come at a future advisory board meeting.

631
01:48:53.520 --> 01:48:58.350
Amanda Kohler: David okay so let's talk about the statutory regulatory framework there's three components here.

632
01:48:59.070 --> 01:49:12.720
Amanda Kohler: The first component comes from the e-Manifest Act, which requires EPA to establish a hazardous waste electronic manifest system that may be used by any user and then the act goes on to define user and we've included a screenshot of that on the slide.

633
01:49:13.890 --> 01:49:16.860
Amanda Kohler: I wanted to point to Section five B little I.

634
01:49:17.940 --> 01:49:27.150
Amanda Kohler: saw a user as a person that elects to use the system which is the e-manifest system to complete and transmit and electronic manifest format.

635
01:49:32.040 --> 01:49:46.560
Amanda Kohler: Okay second component we're at the manifest regulations to 6224 you see electronic manifest this language is the purpose of this language is to explain the electronic manifest of the legal equivalent to paper manifests.

636
01:49:48.210 --> 01:49:58.050
Amanda Kohler: Section a (2) here, though I wanted to point out any requirement and these regulations to give provide send forward or return to another person, a copy of the manifest is satisfied.

637
01:49:58.530 --> 01:50:06.150
Amanda Kohler: When electronic manifest is transmitted to the other person by submission to the system, the system being the e-Manifest system.

638
01:50:07.020 --> 01:50:14.640
Amanda Kohler: And although to 6224 comes from the generator part of the regulations we do have similar language in the transporter and TSDF part of our regs.

639
01:50:15.180 --> 01:50:24.990
Amanda Kohler: And I will mention an astute listener of our meeting last week did point out that the hybrid manifest is an important exception to this, in that the.

640
01:50:25.740 --> 01:50:36.750
Amanda Kohler: The generator isn't getting the copy from the system actually Bryan touched on this a little bit earlier, but the regulations already have that exception built into the regulatory framework, so.

641
01:50:39.870 --> 01:50:42.000
Amanda Kohler: So, if we were to consult sorry David.

642
01:50:43.260 --> 01:50:48.450
Amanda Kohler: So, if we were to consider other exceptions, you know that that may require regulatory change.

643
01:50:49.770 --> 01:50:57.780
Amanda Kohler: All right, third and final component of the statutory regulatory framework is the definition of electronic manifest signature and 262 25.

644
01:50:58.380 --> 01:51:08.670
Amanda Kohler: And so, our definition is a two-part definition one the electronic signature must be a legally valid enforceable signature under applicable EPA and other federal requirements.

645
01:51:09.630 --> 01:51:17.970
Amanda Kohler: And then into it has to be a method that's designed and implemented and manner that EPA considers to be cost effective and practical as possible for the users.

646
01:51:21.180 --> 01:51:38.310
Amanda Kohler: Alright, so what are our main takeaway so as we see it now going through the Act and the regulations, we see we see three requirements so under the manifest act a user must use the system, i.e., manifest system to complete and transmitted electronic manifest format.

647
01:51:40.140 --> 01:51:49.890
Amanda Kohler: requirements that relations to give provide send for to return to another person to copy manifests are satisfied by submission to the manifests by submission to the system.

648
01:51:50.970 --> 01:52:04.110
Amanda Kohler: And then third electronic signature methods for you manifest must be legally valid enforceable and cost effective and practical and so we're going to come back to these requirements, after each of the scenarios that Steve describes, and I'll turn to Steve.

649
01:52:09.420 --> 01:52:24.300
Stephen Donnelly: Thanks man that would like to reiterate that mean a lot of these slides are really important but as far as like this, or the name of the game, right here for the IT system, the program is the future the present and the future are spelled out.

650
01:52:25.770 --> 01:52:31.080
Stephen Donnelly: In in between, was it 4949 to 51.

651
01:52:32.280 --> 01:52:45.210
Stephen Donnelly: there's a lot of there's a lot of great stuff in there for sort of conceptualizing and you're thinking about electronic signatures that's what you want to do, and if you need more information.

652
01:52:46.110 --> 01:52:53.340
Stephen Donnelly: you're craving I'll see and more or less access your information, the slides do have an appendix.

653
01:52:53.820 --> 01:53:06.120
Stephen Donnelly: There is there's a I believe is like 90 slides or something so there's most of the there's a lot of great information electronic signatures and regulations in the back, so please, please do take a look at those but.

654
01:53:07.320 --> 01:53:08.460
Stephen Donnelly: sort of moving on.

655
01:53:09.510 --> 01:53:14.130
Stephen Donnelly: That there are you know, in light of our advisory boards recommendations.

656
01:53:15.300 --> 01:53:35.790
Stephen Donnelly: to sort of expand the idea and the notion of electronic signature the program we see for theoretical option So these are just for theoretical options, there could be more, but we have for us today, so the four number one would be the existing electronic manifesto, I would say that's.

657
01:53:38.130 --> 01:53:40.860
Stephen Donnelly: or conceptual Susan conceptual theoretical in.

658
01:53:42.510 --> 01:53:47.430
Stephen Donnelly: Any case, so we have the first one, which is more than a concept it's real it's what we're using.

659
01:53:47.970 --> 01:54:03.240
Stephen Donnelly: Okay, that we have the second conceptual workflow which would be a user uploads the signature the all the all the all the generator transporter signatures are stored somewhere else, not in the manifest system and then, when the ship, it is complete.

660
01:54:04.650 --> 01:54:13.470
Stephen Donnelly: The manifest is sent the manifesting all the signatures are sent to us at the end upon conclusion, then the.

661
01:54:14.550 --> 01:54:19.290
Stephen Donnelly: The third the conceptual workflows would be the third-party system upload.

662
01:54:20.340 --> 01:54:26.700
Stephen Donnelly: So, this would be a a an application or program actually my dog likes that.

663
01:54:28.140 --> 01:54:28.620
Thanks Doc.

664
01:54:29.970 --> 01:54:42.660
Stephen Donnelly: The third-party system is the intermediary between the manifest system in industry system that at every point of change transfer signature is added that third party system sends that update to the manifest system.

665
01:54:43.050 --> 01:54:52.050
Stephen Donnelly: And then the fourth conceptual workflow would be a user uploads a signature throughout the throughout the system.

666
01:54:52.620 --> 01:55:12.840
Stephen Donnelly: And that would advance math so that would be essentially Amanda would be working at a generator site on the loading dock and test would be the person at the office and but upon notification that Amanda has signed the lecture Amanda has done the electronic manifest.

667
01:55:14.130 --> 01:55:27.420
Stephen Donnelly: things she would notify her, she did my tests and tests would update the system in the manifest would move throughout so basically a system to update our system run by industry systems, but we'll get into more detail.

668
01:55:30.600 --> 01:55:49.890
Stephen Donnelly: Alright, so let's go to the next slide So these are these are something to pay attention to and somebody considered though so so, the blue is a transfer of manifest data or changing says, then the red is the signer updated manifesting that little pin right there.

669
01:55:53.640 --> 01:55:55.290
Stephen Donnelly: I do this, you see a mouse.

670
01:55:56.910 --> 01:55:57.600
Amanda Kohler: I cannot.

671
01:55:59.160 --> 01:56:00.540
Amanda Kohler: keep moving Oh, I see it.

672
01:56:00.570 --> 01:56:11.010
Stephen Donnelly: I see it, okay cool, then the red is the signer updated manifest data, this is a pen fountain Pen, and this is what user interface.

673
01:56:11.430 --> 01:56:26.850
Stephen Donnelly: The user actually sees in this right here, we have our factory or generator factory with the smokestacks that we have our transporter in a box truck and then we have our treatment story and disposal facility, represented by the.

674
01:56:27.870 --> 01:56:33.360
Amanda Kohler: it's like some sort of recycling all right I'll correct the record, if you were trying to point with your cursor. I'm not seeing it.

675
01:56:33.510 --> 01:56:37.080
Stephen Donnelly: Now okay great hi this is, I can control David thanks.

676
01:56:38.280 --> 01:56:42.660
Stephen Donnelly: OK so anyway moving boldly ahead.

677
01:56:44.220 --> 01:56:58.950
Stephen Donnelly: So, let's go to the existing attract manifest workflow I hope you all were paying attention in the first part of the presentation, but essentially this is how it goes the manifest is created in the industry system.

678
01:57:00.600 --> 01:57:11.790
Stephen Donnelly: And in each step along the way the generator or transport and generator transporters receiving facility go into the system to sign the manifest.

679
01:57:14.430 --> 01:57:17.250
Stephen Donnelly: I think we're all aware that oh, thank you very oh that's Oh yes, right Thank you.

680
01:57:18.630 --> 01:57:20.970
Stephen Donnelly: cool so they're in the system to sign the benefits.

681
01:57:22.500 --> 01:57:27.150
Stephen Donnelly: And then, this next slide will ask and answer some important questions.

682
01:57:28.170 --> 01:57:28.950
Stephen Donnelly: So, number one.

683
01:57:30.330 --> 01:57:39.300
Stephen Donnelly: Who needs to be registered everybody needs to be registered to sign so everybody needs to if you want to see the manifest you need to be registered.

684
01:57:39.750 --> 01:57:45.180
Stephen Donnelly: And you need to have site access to these sites named to a site name of the manifest sign it if you were a generator.

685
01:57:45.510 --> 01:57:56.490
Stephen Donnelly: You do have approved site access to the generator site name, but the manifest say, for the transporters same for the received so you need to be registered user, you need to have access to the sites named on the manifest.

686
01:57:57.930 --> 01:58:04.920
Stephen Donnelly: And then to sign the user with login to recruit info navigate to that the manifest.

687
01:58:05.940 --> 01:58:20.430
Stephen Donnelly: And, or if they have a friend who has site manager access, they could use the UI link service to send them a link directly to that manifest and they would click quick setup, so this is where the generating the transporter initial seed.

688
01:58:20.880 --> 01:58:28.440
Stephen Donnelly: So, they need to go in find a manifest and click sign or they can take the shortcut of the UI link click on that and then click side.

689
01:58:32.130 --> 01:58:39.030
Amanda Kohler: So, applying the statutory, regulatory framework to our current electronic manifest workflow you would expect to see a lot of check marks here.

690
01:58:39.750 --> 01:58:50.640
Amanda Kohler: We are using the system to complete and transmit electronic manifests we are transmitting to the other person by submission to the system and our electronic signatures are valid and enforceable.

691
01:58:51.180 --> 01:59:05.730
Amanda Kohler: However, since only a half percent of our total manifest volume or present electronic manifest it's reasonable to conclude that there are questions for whether our electronic signature method is cost effective and practical and so you see us acknowledge that here with a question mark.

692
01:59:10.740 --> 01:59:14.130
Stephen Donnelly: All right, fantastic Okay, we are at a conceptual.

693
01:59:15.300 --> 01:59:21.750
Stephen Donnelly: conceptual framework number two, this is the user uploads signature at the end.

694
01:59:23.370 --> 01:59:31.890
Stephen Donnelly: Okay, so we have here on the left Okay, so the manifest is creating the manifest is created in the manifest system.

695
01:59:32.430 --> 01:59:36.810
Stephen Donnelly: So, this is by the generator transporter or they're seeing the facility.

696
01:59:37.560 --> 01:59:49.620
Stephen Donnelly: And all the handlers are named on the manifest and there is a manifest tracking number, and this gets down so basically this manifest all the all the basic information.

697
01:59:50.610 --> 02:00:00.510
Stephen Donnelly: But then it gets taken out of the manifest system, and it goes into an industry system and there and that industry system, it goes the generator side.

698
02:00:01.290 --> 02:00:12.180
Stephen Donnelly: So, it's not a tablet of some kind of offline it's that made that no one's EMF essence was an old school, so it goes from the transporter because the generator to the transporter.

699
02:00:13.170 --> 02:00:23.460
Stephen Donnelly: To the to the designated facility and all that  electronics in our electronic signature information is captured outside the system and then.

700
02:00:24.810 --> 02:00:34.170
Stephen Donnelly: It is uploaded to the manifest system; I believe 30 days post receipts say so we'll get that information at some points about the electronic signature information.

701
02:00:37.110 --> 02:00:51.690
Stephen Donnelly: Alright, the next slide so who needs to be registered, only one person needs to be registered, this would be the receiving facility so they can use the chrome error compliance signature to submit that final completed manifest.

702
02:00:53.130 --> 02:00:57.690
Stephen Donnelly: and design, as we saw all the users allow that workflow.

703
02:00:58.110 --> 02:01:03.660
Stephen Donnelly: Or would be signing in some sort of industry system, so we don't know what it would look like we don't know what sort of things you may be leaving.

704
02:01:03.960 --> 02:01:15.360
Stephen Donnelly: But we would have no data will be transferred to the EPA manifest until that person at the receiving facility uploads that data and submits that madness.

705
02:01:18.990 --> 02:01:22.770
Amanda Kohler: Okay, so scenario two considers.

706
02:01:23.910 --> 02:01:31.470
Amanda Kohler: an option, where the receiving facility uploads the manifest data and all the electronic signatures, at the end of the process.

707
02:01:32.010 --> 02:01:39.570
Amanda Kohler: So, applying the statutory, regulatory requirements for right now we find it challenging to see how.

708
02:01:40.110 --> 02:01:53.610
Amanda Kohler: we're using the system you manifest to complete and transmit electronic manifest when it's coming all the way at the end, and on the regulatory side again find it challenging for how we're using the system to transmit the manifest copy to another person.

709
02:01:54.780 --> 02:02:02.820
Amanda Kohler: for electronic signatures question marks here and that's because we're considering electronic signatures captured outside of the EPA manifest system and so.

710
02:02:03.900 --> 02:02:10.860
Amanda Kohler: whether and how EPA will determine whether electronic signatures are valid enforceable are cost effective and practical and open question.

711
02:02:12.120 --> 02:02:14.400
Stephen Donnelly: If we just go back to the previous slide really quick.

712
02:02:16.020 --> 02:02:16.500
Stephen Donnelly: I know.

713
02:02:18.000 --> 02:02:29.730
Stephen Donnelly: Yes, what to point out so yeah at every at every step along the way, and this method, so the manifest information is sort of the workflow is being transmitted outside of the industry system outside of the manifest system so.

714
02:02:30.300 --> 02:02:39.750
Stephen Donnelly: The transporter can sign in the industry system, once the generator science, but it's a big question mark here what's going.

715
02:02:42.570 --> 02:02:46.080
Stephen Donnelly: Clear my drawings right, we can move on ahead.

716
02:02:50.700 --> 02:02:57.570
Stephen Donnelly: Okay, so third-party system upload signatures throughout the third-party advances manifest and.

717
02:02:58.770 --> 02:03:13.260
Stephen Donnelly: Not very doesn't really roll off the Tongue this method, however, it is something to consider that so someone will sit be he manifests is created in the EPA says.

718
02:03:14.310 --> 02:03:21.210
Stephen Donnelly: And what would happen here, and this is all this is all conceptual we're not conceptual models, right here is this manifest right here.

719
02:03:22.050 --> 02:03:33.000
Stephen Donnelly: gets put into a third-party system so it's a third-party device cloud applications something like that to go to be to get signatures so.

720
02:03:33.960 --> 02:03:43.500
Stephen Donnelly: The manifest created all the hammers run it all good to go it's at the loading dock and I'm on the loading dock and I just need to see whatever is on.

721
02:03:43.920 --> 02:03:52.170
Stephen Donnelly: Whatever is on my iPhone and on the generator and I write my name, or I check a box, or I signed something with my signature information.

722
02:03:52.530 --> 02:04:03.630
Stephen Donnelly: And I'm not saying I'm not logged into the manifest system, however I'm in this third-party system and once I sign this third-party system sends that info back up.

723
02:04:04.530 --> 02:04:18.030
Stephen Donnelly: To the manifest system, so now parties on the manifest or state regulators EPA regulators to see that okay this manifest was signed by the generator at this point, time and there's a shipment.

724
02:04:19.230 --> 02:04:37.950
Stephen Donnelly: The shipment has transpired, and then, once that signed from once the generator side the transport will sign that information will go back up and then it'll go through the workflow such that, so no one's signing into the manifest, but a third party is telling you manifest hey.

725
02:04:39.780 --> 02:04:45.000
Stephen Donnelly: Steve sided Amanda sided test cited and that's how the workflow goes until the end.

726
02:04:50.310 --> 02:05:00.120
Stephen Donnelly: Okay, so who needs to be registered, similar to the last conceptual model, the receiving facility so they can use that chrome error compliance into to submit the final completed manifest.

727
02:05:01.950 --> 02:05:14.250
Stephen Donnelly: And then to sign the users must be able to access that a third-party system by a verified communication email phone user account and.

728
02:05:15.240 --> 02:05:31.770
Stephen Donnelly: Just sort of spell this out plenty as possible this verification means they can access that account and that third party system to sign this is not a verification of an individual individuals ID like the electronic signature agreement we have in recruiting.

729
02:05:36.300 --> 02:05:38.970
Amanda Kohler: Okay, so you know, the biggest difference.

730
02:05:39.690 --> 02:05:50.550
Amanda Kohler: scenario three compared to scenario two is that scenario two envisions all the manifest data and electronic signatures coming in at the end and as Steve just described scenario three has that manifest data.

731
02:05:51.090 --> 02:06:01.530
Amanda Kohler: uploading to our system throughout the process, so scenario three is a bit better of a fit here as, according to the e-Manifest Act, the system is being used to complete.

732
02:06:02.190 --> 02:06:11.550
Amanda Kohler: and transmit electronic manifest we do have a question mark here just on whether we whether where we land on what transmit means and so.

733
02:06:12.510 --> 02:06:15.600
Amanda Kohler: So that is an open question as far as the regulatory requirements.

734
02:06:16.170 --> 02:06:20.490
Amanda Kohler: Are we transmitting to the person by submissions in the system, right now, are leaning is.

735
02:06:20.790 --> 02:06:29.760
Amanda Kohler: This criteria would not be met, just because the manifest is advancing outside of the system and so we're not transmitting to another person using the system.

736
02:06:30.390 --> 02:06:41.730
Amanda Kohler: And then question marks for electronic signatures for the same reason as we described in scenario to these are electronic signatures happening outside of e-Manifest and so whether and how EPA would ensure that.

737
02:06:42.330 --> 02:06:48.600
Amanda Kohler: That industry system electronic signatures would be valid enforceable and cost effective and practical isn't an open question.

738
02:06:52.650 --> 02:07:05.190
Stephen Donnelly: All right now here we go this is for user uploads signatures real out in the manifest system advances manifest so for those of you who remember.

739
02:07:05.880 --> 02:07:11.340
Stephen Donnelly: One of our advisory board meetings I can't remember which one we sort of talked about if this was um.

740
02:07:11.910 --> 02:07:20.190
Stephen Donnelly: This is April 2020 we talked about this is a this was also known as the one-person registered solution that David Graham expand upon.

741
02:07:21.060 --> 02:07:42.090
Stephen Donnelly: When it comes to capturing electronic signatures, so this is the signature is uploaded throughout the shipment by the industry system in the industries in the manifest this will be dances that so forth, it so that so our manifest is created, all the handles are on it.

742
02:07:43.110 --> 02:07:51.780
Stephen Donnelly: All that all that fun stuff everything you need to everything you possibly want on your manifest is on your manifest and the shipment can begin.

743
02:07:53.310 --> 02:08:08.940
Stephen Donnelly: Okay, however, one of the interesting things here is that I'm going to sort of spoil thing around this, but so each site along the shift that needs a site manager someone with an API DMK like managers like manager.

744
02:08:10.290 --> 02:08:22.350
Stephen Donnelly: And of course, I matter here is an API ID and key to pass a signature information back so for the purposes of this demonstration right here.

745
02:08:23.460 --> 02:08:39.570
Stephen Donnelly: hi the generator sites and I am the site manager and Scott is the person on the loading dock so that that I know Scott has notified me that the manifest shipment it has gone he has.

746
02:08:41.190 --> 02:08:53.010
Stephen Donnelly: he's accessed whatever industry system we have at our at our generator side and basically let's that industry system know that hey I signed that manifest.

747
02:08:54.150 --> 02:09:06.270
Stephen Donnelly: me being the same manager, I see that Scott has signed that manifest and what I do, since I am the site manager here is I send back that information to the manifest system saying.

748
02:09:06.960 --> 02:09:26.310
Stephen Donnelly: I inbox 15 Scott Christian has signed at on 11 3025 you know I send back that information, so it goes back here I send that information so then that goes to the transporter it goes down the transporter and that transporter lets their site manager.

749
02:09:27.600 --> 02:09:34.140
Stephen Donnelly: let you know influence our site manager through an electronic system of some kind, that they've signed the manifest in that information goes back up.

750
02:09:34.530 --> 02:09:48.330
Stephen Donnelly: And threw in through the workflow process, so the site manager is updating the manifest with the signature information from their onset person.

751
02:09:51.330 --> 02:10:01.860
Stephen Donnelly: When you go to the next slide Okay, who needs to be registered so sort of spoiled it, but each party on the manifest needs to have a site manager, with an API key.

752
02:10:03.600 --> 02:10:05.310
Stephen Donnelly: As well as.

753
02:10:07.320 --> 02:10:18.660
Stephen Donnelly: And so, to sign the users will click sign in the industry system which updates the manifest system for the API and also sort of point out here, we talked about site managers.

754
02:10:19.470 --> 02:10:26.430
Stephen Donnelly: there's each site can have we actually recommend having multiple site managers per se at least two just for redundancy.

755
02:10:26.790 --> 02:10:40.590
Stephen Donnelly: So, this could be managing uploaded this information that Scott sign manifest could be uploaded by any number of site managers associated with that with that specific sites over met Amanda was as a manager if Graham tasks.

756
02:10:41.100 --> 02:10:45.510
Stephen Donnelly: Anybody at their site my hair pro site manager that's like they could send back that information.

757
02:10:47.340 --> 02:10:59.190
Stephen Donnelly: and also, the users can use a quick side button in the manifest interface, like the current workbook so like this could be mixed and matched with our current system, so, for example.

758
02:11:00.540 --> 02:11:17.310
Stephen Donnelly: I am I, the generator side, we have a system that could potentially work with this, I let it know that's got a side, however Amanda as a transporter they don't have an industry system, she does logs into the manifest APP and.

759
02:11:18.390 --> 02:11:35.160
Stephen Donnelly: clicks click sign and David Grann his transporter company, they have a system, so he goes into their system, and they update that information, so it can be used to mix and match, and then, as always, the conclusion the manifest assigned a clear compliant signature.

760
02:11:39.030 --> 02:11:49.920
Amanda Kohler: So. scenario four is similar to scenario three except the manifests advances in the manifest in scenario four, and so this is, you know the scenarios.

761
02:11:50.400 --> 02:12:04.320
Amanda Kohler: Two through four, and this is probably the best fit for existing statute and regulatory requirements, because the manifest is advancing our system, we are using the system to complete and transmit electronic manifest we're transmitting to the other person by using the system.

762
02:12:05.940 --> 02:12:13.560
Amanda Kohler: Again, electronic signatures are question marks here just because a scenario for does involve electronic signatures captured outside of e-Manifest and so.

763
02:12:13.770 --> 02:12:28.920
Amanda Kohler: whether and how we would determine valid enforceable and cost effective and practical are open questions, and with that we've talked a lot about valid enforceable, so I let's unpack that here so I'm gonna turn it over to Tess to talk about some hallmarks of that term of art.

764
02:12:30.570 --> 02:12:40.230
Tess Fields: it's Amanda yeah exactly so valid and enforceable is the language used into 16 to 25 about electronic signatures So what does that actually mean.

765
02:12:40.530 --> 02:12:44.910
Tess Fields: And what does that mean in terms of other systems potentially capturing electronic signatures.

766
02:12:45.600 --> 02:12:56.940
Tess Fields: So, the CIO has put out a guidance document of five hallmarks that are typically considered parts of valid and enforceable signatures, and this isn't something that EPA is formulated opted, but rather.

767
02:12:57.960 --> 02:13:00.870
Tess Fields: We think it provides good guidance for what is needed.

768
02:13:03.630 --> 02:13:05.010
Tess Fields: So next slide.

769
02:13:07.020 --> 02:13:19.110
Tess Fields: So, the first hallmark is the form of the signature itself electronic forms of signature can include symbols, such as a typed name a digitized image of a handwritten signature a shared numerical code.

770
02:13:19.890 --> 02:13:33.990
Tess Fields: A fingerprint sounds such as a voice recording processes such as you know, using a mouse to click I agree or logging in with a private key to apply a digital signature.

771
02:13:35.160 --> 02:13:44.190
Tess Fields: This isn't an exhaustive list of forms of electronic signatures also, but it provides it illustrates the variety of options.

772
02:13:47.880 --> 02:13:58.080
Tess Fields: The second home market is the intent to sign so in electronic transactions merely applying a sound similar process doesn't make it a legally.

773
02:13:58.680 --> 02:14:07.650
Tess Fields: Binding signature, it must be implied by the signer with the intent to sign, so when designing a signing process to evidence and intent to sign.

774
02:14:08.070 --> 02:14:16.800
Tess Fields: it's very important to distinguish intend to sign from the reason for signing so, for example, applying a signature is different than just writing your name in a form.

775
02:14:17.970 --> 02:14:29.340
Tess Fields: And the overall signing process should be designed to minimize the risk that signers could legitimately claim that they applied in electronic form signature accidentally without realizing it's legal significance.

776
02:14:33.150 --> 02:14:47.670
Tess Fields: The third hallmark is the association of the signature to the record so just with just as with a paper signature electronic signatures are required to be attached to or associated in some way with the record being signed.

777
02:14:48.720 --> 02:14:57.450
Tess Fields: And there are two aspects to this issue, the first is that the signer must have the opportunity to review the entirety of the record before signing it.

778
02:14:58.350 --> 02:15:04.440
Tess Fields: And the second is that the electronic signature must be linked to the record being signed in some way.

779
02:15:04.980 --> 02:15:20.940
Tess Fields: And for an electronic signature to be equivalent to a signature on a paper document the sound symbol or process that constitutes that electronic signature must be tied to the electronic record and must allow someone to later go back and determine that the record has been summoned.

780
02:15:25.710 --> 02:15:40.050
Tess Fields: The fourth is the identification and authentication of the signer so, by definition, a signature must be the act of a specific signer, and this requires establishing a link between an identified person and the signature.

781
02:15:41.760 --> 02:16:01.800
Tess Fields: Other security procedures may be used to accomplish this objective, so it might include logging into a particular website with a unique username and password and that can then be used to authenticate the signer in the overall process of signing the electronic records.

782
02:16:04.350 --> 02:16:22.410
Tess Fields: Finally, the last call mark is the integrity of the sign record, so it has to be linked the signature has to be linked to the record, but it also must then not be changed after the person has signed the record so.

783
02:16:23.850 --> 02:16:38.220
Tess Fields: It requires that systems, ensure the continuing integrity of both the electronic record and its electronic signature following the completion of the signing process and, since a matter of providing appropriate data security.

784
02:16:38.730 --> 02:16:51.840
Tess Fields: And 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 a document signed electronically is not has not changed once it's been signed.

785
02:16:53.730 --> 02:17:00.090
Tess Fields: So now we'll go into some more time for discussion and questions and.

786
02:17:00.870 --> 02:17:09.720
Tess Fields: Similar to last time I'm going to go through and read the questions and, if you would like to provide feedback raise your hand and I'll call on you in the order that.

787
02:17:10.530 --> 02:17:23.700
Tess Fields: You have raised your hand and then Brian will again go through the written Q & A box afterwards, so we have a bunch of discussion prompts that we actually have two slides of discussion questions this time so I'm just going to read through all of them and.

788
02:17:26.130 --> 02:17:27.630
Tess Fields: Then I'll start taking hands.

789
02:17:28.770 --> 02:17:37.650
Tess Fields: So, what are your thoughts on allowing users to capture and upload electronic signatures and terms of its likelihood to increase electronic adoption.

790
02:17:38.670 --> 02:17:44.100
Tess Fields: previously discussed electronic signature method options and the extent they would encourage adoption.

791
02:17:44.910 --> 02:18:00.690
Tess Fields: whether and how, for example in guidance we define valid and enforceable electronic signature for electronic signatures captured outside the manifest whether we should adopt those CIO guidance for the five hallmarks of valid and enforceable signature.

792
02:18:02.430 --> 02:18:17.790
Tess Fields: I'll read the next one, to what are your thoughts on whether EPA should be responsible for ensuring that industry systems meet requirements, whether EPA should be concerned about ensuring the manifest isn't altered between dockworker and site manager.

793
02:18:18.810 --> 02:18:29.880
Tess Fields: And whether EPA should require simultaneous direct connection upload the manifest compared to allowing users to save on their system for some time before uploading.

794
02:18:30.750 --> 02:18:35.250
Tess Fields: And prior to advancing the manifest and what are the potential offline impacts.

795
02:18:36.150 --> 02:18:49.980
Tess Fields: So, if you have thoughts on any of these questions or, if you want us to go back to a particular slide to talk about something Please go ahead and raise your hand I see angel has raised his hand again, so please go ahead and unmute yourself angel.

796
02:18:55.980 --> 02:18:57.630
Tess Fields: Still muted if you're trying to talk.

797
02:19:04.830 --> 02:19:13.920
Tess Fields: And perhaps angel stepped away for a moment, so I will come back to but Larry if you would like to unmute yourself.

798
02:19:14.340 --> 02:19:16.020
Larry Fura: Sure, can you hear me.

799
02:19:16.230 --> 02:19:17.400
Larry Fura: Yes, great.

800
02:19:18.660 --> 02:19:20.610
Larry Fura: So. I just want to clarify.

801
02:19:21.660 --> 02:19:27.900
Larry Fura: A couple things like if we went back to the second scenario slide.

802
02:19:34.080 --> 02:19:37.020
Larry Fura: Okay, and I asked this also in the in the questions but.

803
02:19:37.170 --> 02:19:38.970
Larry Fura: So. you can just ignore them when they get to that, but.

804
02:19:39.540 --> 02:19:50.100
Larry Fura: I mean, in this case the signatures, I know this is conceptual right now, but this would be potentially somebody drawing their finger on an iPad.

805
02:19:51.210 --> 02:19:52.800
Larry Fura: Using a signature pad.

806
02:19:54.420 --> 02:20:14.250
Larry Fura: You know, some method, but it doesn't have to be a specific sign in. but an industry system could capture that in this scenario, and then they would basically just upload them at the end of the process in this scenario, that is the correct what you're what you're getting at with this.

807
02:20:17.250 --> 02:20:19.800
Larry Fura: I don't know Scott, maybe clarify that or Brian.

808
02:20:20.070 --> 02:20:30.240
Bryan Groce: And I'll defer to Skype but uh the answer to that question in general for these options that are discussed for three and four is yes, that.

809
02:20:30.870 --> 02:20:49.440
Bryan Groce: You know the expectation would be that the signatures would not occur within our system they would occur outside of ours, and this is sort of trying to flesh out to figure out how such signatures or turn a sentence would meet those five hallmarks at the test just addressed.

810
02:20:49.680 --> 02:20:54.450
Stephen Donnelly: Okay, so yeah Larry, this is the so yeah Essentially, it would be.

811
02:20:55.740 --> 02:21:00.540
Stephen Donnelly: It would be, it would be the equivalent of a paper manifest method.

812
02:21:01.680 --> 02:21:07.830
Stephen Donnelly: yeah, sort of concept to would be, it would be completely outside of the system we wouldn't know what was going on until via.

813
02:21:08.430 --> 02:21:13.410
Larry Fura: Okay sounds good, and then, if we advance the slide three and then Scott, maybe just be ready.

814
02:21:15.570 --> 02:21:24.390
Larry Fura: slide three is you're having this third party basically capture whatever form of signature new signature method that would be allowed.

815
02:21:26.190 --> 02:21:28.410
Larry Fura: I guess, my question is with that would be.

816
02:21:29.730 --> 02:21:43.380
Larry Fura: Is there a reason why you want to involve a third-party or couldn't EPA simply provide some of these simpler capture methods couldn't the industry user you know simply call an API and.

817
02:21:44.220 --> 02:21:50.880
Larry Fura: You know, get back a link that would pop up screen that the user could then sign with their finger, but EPA is providing that.

818
02:21:51.390 --> 02:21:56.820
Larry Fura: That service or like I thought about texting, you know if a user's got a cell phone number.

819
02:21:57.300 --> 02:22:08.310
Larry Fura: EPA could initiate a. you know, an interactive voice response system that would call the user and ask, have you reviewed the manifest you know press one for yes two for no and then you know.

820
02:22:09.060 --> 02:22:15.600
Larry Fura: Do you want to sign this manifest one for yes two for no and it goes through, but rather than involve this third party.

821
02:22:17.370 --> 02:22:28.590
Larry Fura: It would seem to make more sense to me to have EPA just simply provide those kind of simpler signing alternatives if you decided that this kind of signature was going to be allowed.

822
02:22:30.630 --> 02:22:42.870
Larry Fura: For what it's worth I don't know if you have any reason from an EPA perspective that you wouldn't want to and want to involve a third party, I mean if it's just a cost thing development time something like that or, if you have any comments on that.

823
02:22:52.110 --> 02:22:53.820
Stephen Donnelly: What if.

824
02:22:54.570 --> 02:23:05.160
Scott Christian: These are all their options so just trying to flesh out the options and get people's comments on the various options so third party would be it could be a third party.

825
02:23:06.420 --> 02:23:10.680
Scott Christian: system that you may use to sign mortgages and things like that.

826
02:23:12.750 --> 02:23:20.580
Scott Christian: There are options that could be and to your point about additional signature options that he could offer.

827
02:23:22.410 --> 02:23:23.340
Scott Christian: Those are definitely.

828
02:23:24.450 --> 02:23:25.710
Scott Christian: Good places to comment.

829
02:23:27.900 --> 02:23:42.360
Scott Christian: You know the idea of text has come up in the past, so if people would use it, then we can discuss that internally, so that the main reason is getting those comments I appreciate the question.

830
02:23:44.340 --> 02:23:59.970
Amanda Kohler: yeah, all add that we propose something for advisory board consideration was that April 2020 that was similar using links to via text or via phone and you know heard that there would be challenges with.

831
02:24:00.990 --> 02:24:07.410
Amanda Kohler: The system, knowing the unique emails the unique phone numbers for each of the signers and so.

832
02:24:08.430 --> 02:24:13.230
Amanda Kohler: And so, I think scenario for is probably maybe David can flip there.

833
02:24:14.610 --> 02:24:25.140
Amanda Kohler: But in order to maybe meet that hallmark of identifying authenticate you know here we're allowing the dockworker and the driver to to sign, however, the company.

834
02:24:25.500 --> 02:24:32.790
Amanda Kohler: wants to capture those electronic signatures, but then using the site manager encrypted unique ID and key to send it to the manifest and so.

835
02:24:33.750 --> 02:24:42.120
Amanda Kohler: So, we don't necessarily the system doesn't need to know the phone number of the dock worker or the email at the dock worker or have the even the dockworker driver registered.

836
02:24:42.810 --> 02:24:53.730
Amanda Kohler: And so, we're hoping that kind of that helps address a big challenge we have heard throughout the Advisory Board process, but at the same time, we have a site manager registered for each site and that's site manager is then uploading.

837
02:24:54.510 --> 02:25:01.980
Amanda Kohler: That electronic signature that they have captured from the driver of the dockworker you know to manifest and so that whole process, then, is.

838
02:25:02.340 --> 02:25:16.380
Amanda Kohler: is providing us the assurances of the person on the docket in the truck that's acknowledging receipt, or you know certifying that they prepare the shipment but also having that site manager already registered already known to the to the system and allowing us to authenticate that way.

839
02:25:17.940 --> 02:25:21.450
Larry Fura: I guess with number four when Scott was explaining it.

840
02:25:23.100 --> 02:25:33.810
Larry Fura: What I took from it was like a Doc manager could call some other person, that is, the site manager at the site and just simply say Okay, I signed for this and that site managers and going to say.

841
02:25:34.200 --> 02:25:47.880
Larry Fura: Great Larry signed for it at this time and submit that to the manifest, but it would seem like that would technically break the identity and authentication piece that test covered.

842
02:25:49.140 --> 02:25:51.630
Larry Fura: If EPA did adopt that is.

843
02:25:52.830 --> 02:25:56.130
Larry Fura: A signature, the different electronic forms of signature.

844
02:25:57.810 --> 02:26:13.470
Larry Fura: Because I don't know what would stop that you know it stopped at from site manager from simply saying yep okay that's correct and I guess, one of the questions I would have on scenario for while we're looking at this, like to is could a site manager from.

845
02:26:14.640 --> 02:26:17.430
Larry Fura: Any of those phases.

846
02:26:18.870 --> 02:26:26.880
Larry Fura: complete the signature for the other phases, in other words, could the transporter get their site manager person on the phone.

847
02:26:27.390 --> 02:26:39.420
Larry Fura: and say I'm signing this manifest and I'm here with the generator I'm here with Larry is signing the manifest and put me on the phone with them and say, yes, I wonder sign it, and the transporters.

848
02:26:41.130 --> 02:26:41.640
Larry Fura: You know.

849
02:26:42.900 --> 02:26:50.790
Larry Fura: site manager would be able to enter signatures for both of us I'd be curious to know if there was any thought given to that.

850
02:26:52.650 --> 02:26:53.370
Larry Fura: So.

851
02:26:55.500 --> 02:26:59.730
Amanda Kohler: yeah, well I'll say this is this is early stages, and so we are.

852
02:26:59.790 --> 02:27:07.260
Amanda Kohler: We are very interested in stakeholder input on on how flexible or stringent to be in terms of.

853
02:27:08.340 --> 02:27:15.270
Amanda Kohler: Setting requirements for electronic signatures captured outside of the manifest, and so the five hallmarks that Tess went through is something that.

854
02:27:15.780 --> 02:27:23.220
Amanda Kohler: You know, we found helpful and just adds to the conversation I will point out the identify authenticate hallmark, which is in that guidance.

855
02:27:23.760 --> 02:27:39.960
Amanda Kohler: Does count the overall process, so you don't actually have to do the identify and authenticate in the actual one signature step it can be the overall process and so that's how we see scenario four working that way but yes, you know we're very interested in in that okay.

856
02:27:40.260 --> 02:27:52.080
Larry Fura: The other only other comment I would make about this in all cases where you're showing industry system, I think it would be beneficial to break you know to break those up that each.

857
02:27:53.130 --> 02:28:00.660
Larry Fura: Part could have their own industry system, the, you know the generator could log into a manifest into the current web portal and sign.

858
02:28:00.990 --> 02:28:14.010
Larry Fura: And then the transporter could use their industry system to you sign versus you know the way it's depicted yeah there you go yeah something more like that yeah good you've covered that um.

859
02:28:15.540 --> 02:28:16.650
Larry Fura: I think that.

860
02:28:18.000 --> 02:28:19.110
Stephen Donnelly: In the appendix.

861
02:28:19.170 --> 02:28:19.470
yeah.

862
02:28:20.580 --> 02:28:28.620
Larry Fura: The only other, the only other comment I wanted to make or question to ask is at all these points where you're receiving a signature.

863
02:28:29.460 --> 02:28:38.400
Larry Fura: I'm assuming that it if you're not assuming this I would, I would say that you would want to assume that you're also going to get a text version.

864
02:28:39.150 --> 02:28:43.470
Larry Fura: You know text meeting typed type diversion of the name of the person that signing.

865
02:28:43.830 --> 02:28:51.450
Larry Fura: So, if somebody signing on a signature pad or with their finger whatever somewhere somebody's typing in the name of that person.

866
02:28:51.780 --> 02:28:58.770
Larry Fura: so that you know who that signature is supposed to belong to whether or not that person is registered with the manifest or not, you know.

867
02:28:59.430 --> 02:29:10.860
Larry Fura: Because it sounds like, in this case the person with all these signature scenarios that you're proposing, except for option one all of those are with users, that may or may not have accounts with a manifest so.

868
02:29:12.420 --> 02:29:22.470
Larry Fura: You know you're just talking to whoever's at the site they're signing out the generator site they're going to say my name is so, and so, and then they're going to sign them the signature pad kind of idea so.

869
02:29:23.610 --> 02:29:32.190
Amanda Kohler: And I'll add to I think we're even more open to two formats of electronic signature, so, you know, the first hallmark that test described.

870
02:29:32.790 --> 02:29:42.180
Amanda Kohler: talked about a whole different in a whole set of formats so type names, you know initials certainly digitize handwritten signatures.

871
02:29:43.080 --> 02:29:53.580
Amanda Kohler: voice recording you know it's a very it's very flexible, at least with respect to this guidance that talks about this, and so what we adopted or not, you know that's open.

872
02:29:54.660 --> 02:29:59.700
Larry Fura: yeah, I mean I I'd be for having you adopted, but the key I guess was just even knowing.

873
02:30:00.720 --> 02:30:08.880
Larry Fura: You know, knowing that identity of that person to tie with whatever type of signature they provided I think would be helpful.

874
02:30:09.930 --> 02:30:10.230
Amanda Kohler: So.

875
02:30:10.980 --> 02:30:11.250
Larry Fura: that's.

876
02:30:11.910 --> 02:30:13.260
Larry Fura: Those are the questions I have, thank you.

877
02:30:17.070 --> 02:30:20.340
Larry Fura: Oh, and what sorry one other thing I was in touch with two, which is just the.

878
02:30:21.090 --> 02:30:32.310
Larry Fura: uploading at a later point I don't think is a problem, and that would address a lot of the concerns of somebody being offline not having Internet or cellular capabilities, so I think that's worthwhile to.

879
02:30:32.670 --> 02:30:36.030
Larry Fura: definitely try to pursue if they can upload it later, no, no again.

880
02:30:36.540 --> 02:30:45.600
Larry Fura: I don't think you have to be as rigid as it only gets uploaded at the end, it could be the idea that it gets uploaded at some point along the process or multiple points along the process.

881
02:30:45.930 --> 02:30:50.370
Larry Fura: You know so as soon as somebody comes back into a cellular connection, they can upload what they have.

882
02:30:52.500 --> 02:30:59.730
Amanda Kohler: yeah, thank you for that yeah for scenario for similar is uploading before the next signature, for example, yeah.

883
02:31:03.090 --> 02:31:03.600
Tess Fields: And Claire.

884
02:31:03.840 --> 02:31:08.850
Tess Fields: X angel I see that you were able to unmute yourself, would you like to.

885
02:31:09.960 --> 02:31:15.420
Angel: Yes, and Mike my question is in is in the same line as a previous.

886
02:31:16.890 --> 02:31:17.490
Angel: person.

887
02:31:18.630 --> 02:31:24.690
Angel: Before this last one in regards to the signature system or a manifest system.

888
02:31:27.720 --> 02:31:40.140
Angel: Is the generator required to purchase their own system for e- signatures or is the EPA going to provide that to the generators, or is it a system that the generator can log into to do this.

889
02:31:43.560 --> 02:31:46.980
Stephen Donnelly: yeah so, we do provide yeah, the manifest system is.

890
02:31:48.150 --> 02:31:53.550
Stephen Donnelly: Free for people, the EPA he manifests charges is the receiving facilities for the submission of the manifest.

891
02:31:54.060 --> 02:32:03.030
Stephen Donnelly: We have an ETA system that is a user interface, that is used by the generators to sign manifest and download data there's a lot of the reports in there.

892
02:32:03.990 --> 02:32:15.600
Stephen Donnelly: And also, we saw you know we have you know, a sort of a you could also use manifest without having to log in the manifest using the services, however, your mileage may vary on if you want someone to build you something.

893
02:32:16.020 --> 02:32:24.960
Stephen Donnelly: or building yourself custom, you know, using our data services that could cost money, but we do have a web interface, that is really nice and for us.

894
02:32:26.220 --> 02:32:27.060
Angel: Oh, that's good to hear.

895
02:32:27.600 --> 02:32:34.620
Angel: The other questions are TSDFs already using a manifest and transporters.

896
02:32:37.680 --> 02:32:39.780
Stephen Donnelly: Yes, yeah, I can we can.

897
02:32:40.860 --> 02:32:56.520
Stephen Donnelly: We can throw together some percentages of the receiving facility is a transport is using he manifests we do have we do have a small but growing number of sites using he manifests every month, so.

898
02:32:57.030 --> 02:33:04.530
Stephen Donnelly: Since we deployed quick sign and December of 2020, we have seen a.

899
02:33:05.010 --> 02:33:08.370
Stephen Donnelly: See, we see an increase in electronic map, so we can.

900
02:33:08.670 --> 02:33:18.150
Stephen Donnelly: We can certainly look at some of the numbers percentage wise is that going to be salary job we've gone from you know roughly 450 manifest a month electronic manifest you.

901
02:33:18.480 --> 02:33:25.680
Stephen Donnelly: Know we're nearing six 700 men electronic manifesting a month, which is good it's an improvement.

902
02:33:26.550 --> 02:33:37.230
Stephen Donnelly: So, we will look at that and some percentages of sites, but if you are, if you are listening if you're not registered, please register contacts contact the team, and we will help you get going.

903
02:33:38.220 --> 02:33:45.660
Amanda Kohler: And just from a high-level response, Angel, to your question, so we have an electronic manifest system, right now, people can use.

904
02:33:46.440 --> 02:33:57.480
Amanda Kohler: But the but what we're seeing is not a lot of people are using it, and so what we've heard from our advisory board and our users is that other options that allow for better integration with.

905
02:33:58.440 --> 02:34:13.710
Amanda Kohler: manifesting systems that are being used by companies would help increase adoption and so that's why we're here today, so I want to make clear that we have an electronic manifest workflow. and it works and people are using it just not a lot so hoping to increase that so.

906
02:34:14.580 --> 02:34:19.950
Angel: So. you seem to get it fully adopted so it's currently not fully adopted.

907
02:34:22.260 --> 02:34:36.210
Amanda Kohler: So, so we collect all manifest paper and electronic so most of the manifest that we collect in our manifest system are coming into us in paper manifest format, either through an image upload or image plus data.

908
02:34:37.620 --> 02:34:43.890
Amanda Kohler: And a small subset is coming in, is fully electronic or hybrid and we want to increase that subset of electronic manifests.

909
02:34:44.880 --> 02:34:46.500
Angel: Okay yeah.

910
02:34:46.590 --> 02:34:55.110
Bryan Groce: This is Bryan, I just wanted to mention that as Amanda said, the system is available for us, however, generators are not.

911
02:34:56.310 --> 02:35:05.640
Bryan Groce: required to use the system, in other words, they can continue to track their shipments on paper with the manifest form that form ultimately will be.

912
02:35:06.270 --> 02:35:12.450
Bryan Groce: That final copy will be uploaded once the doesn't necessarily signs, it will be uploaded into the system.

913
02:35:13.050 --> 02:35:24.990
Bryan Groce: So, however, if a generator wants to participate in electronic workflow they have to register as well as the transporter and as a facility that's captured on the forum on there.

914
02:35:25.650 --> 02:35:33.120
Bryan Groce: are a part of that that shipment I should say, all parties would have to be registered for that electronic workflow.

915
02:35:34.230 --> 02:35:40.590
Angel: Okay got that so it wouldn't do me any good to register as a generator if the transporters not registered as a.

916
02:35:41.910 --> 02:35:42.750
Angel: manifest user.

917
02:35:43.470 --> 02:35:53.580
Bryan Groce: Well, in terms of tracking your shipments know but as far as the record keeping aspect of it and the that final copy, as I said, the.

918
02:35:54.060 --> 02:36:07.050
Bryan Groce: The President of Sony has to upload that paper copy to the system, and you could use that because you have access to it, that would be your copy of record on file another which you wouldn't have to keep a separate copy on file at your site.

919
02:36:07.770 --> 02:36:12.600
Amanda Kohler: And also, yeah Thank you Bryan absolutely and it also enables you to make corrections to your.

920
02:36:12.600 --> 02:36:13.380
Bryan Groce: manifested yes.

921
02:36:13.740 --> 02:36:14.340
Exactly.

922
02:36:15.810 --> 02:36:21.540
Angel: Okay, and regulators will also have access to that for when they do an inspection.

923
02:36:22.140 --> 02:36:23.160
Angel: A site inspections.

924
02:36:23.250 --> 02:36:23.760
Amanda Kohler: Yes.

925
02:36:23.850 --> 02:36:37.800
Bryan Groce: Okay, so that, yes, so that's one added benefit that the regulators can actually if you're registered could go to the site. I'm sorry to the system for your manifests as opposed to ask them to provide them at your site.

926
02:36:38.490 --> 02:36:39.390
Angel: On their visit and care.

927
02:36:41.670 --> 02:36:46.110
Angel: Of one thing that positive on that is that they'll save on.

928
02:36:47.160 --> 02:36:49.110
Angel: Documents space and file cabinets.

929
02:36:49.230 --> 02:36:51.120
Amanda Kohler: Absolutely yeah.

930
02:36:52.200 --> 02:36:53.670
Angel: won't have to kill so many trees.

931
02:36:54.870 --> 02:36:55.320
Stephen Donnelly: Though.

932
02:36:55.770 --> 02:36:56.940
Amanda Kohler: Thank you, Angel, for being here.

933
02:36:56.970 --> 02:36:57.540
Stephen Donnelly: Yes, thank you.

934
02:36:58.200 --> 02:36:58.590
Angel: Thank you.

935
02:37:01.950 --> 02:37:05.010
Tess Fields: yeah, Thank you I'm Robert I see.

936
02:37:06.900 --> 02:37:08.730
Tess Fields: Would you like to unmute yourself.

937
02:37:10.350 --> 02:37:14.520
Robert Fronczak: yeah, it occurs to me that in options, you know.

938
02:37:14.550 --> 02:37:15.840
Tess Fields: two, three and four that.

939
02:37:16.350 --> 02:37:24.120
Robert Fronczak: The railroad EDI system might be act as the quote industry system and are you guys open to that.

940
02:37:29.160 --> 02:37:30.810
Robert Fronczak: I'm not asking for a commitment.

941
02:37:34.650 --> 02:37:38.970
Amanda Kohler: I'm not as familiar with EDI so maybe Steve or Scott can weigh in.

942
02:37:41.700 --> 02:37:44.220
Stephen Donnelly: yeah, this is Steve, we are always happy to

943
02:37:45.540 --> 02:37:52.170
Stephen Donnelly: Work with the railroads and you know take I take a little bit VDI says, I know that's something you guys have.

944
02:37:53.670 --> 02:38:07.290
Stephen Donnelly: it's been around for a while and there's a 262 and 63 so we're talking about railroads and signatures so yeah that's something we are, we are exploring all options to get more electronic manifesto nothing.

945
02:38:10.200 --> 02:38:21.120
Stephen Donnelly: When I say on what that's what I given hard nose to a lot so when we give a hard know it's, pretty it's a hard, no, but we know we are looking we'll take a look at that and we will be in contact.

946
02:38:21.600 --> 02:38:23.910
Robert Fronczak: And we've been using it for over 40 years.

947
02:38:28.590 --> 02:38:29.190
Robert Fronczak: Thank you.

948
02:38:31.560 --> 02:38:32.490
Tess Fields: yeah, Thank you Robert.

949
02:38:37.170 --> 02:38:38.610
Tess Fields: I see Renee.

950
02:38:39.660 --> 02:38:41.130
Tess Fields: First, your hand, would you like to.

951
02:38:42.600 --> 02:38:45.210
Tess Fields: provide feedback or ask the question, yes.

952
02:38:46.830 --> 02:38:47.880
Tess Fields: you're a little muffled.

953
02:38:51.450 --> 02:38:51.840
Renee Nygaard: Better.

954
02:38:52.410 --> 02:38:53.460
Tess Fields: yeah, that is a little better.

955
02:38:54.750 --> 02:39:01.980
Renee Nygaard: um yeah, thank you for contacting us, I just wanted to give a little bit of feedback, I think you might see.

956
02:39:03.150 --> 02:39:14.070
Renee Nygaard: Lower numbers, I feel like the transporter cooperation part is obviously unnecessary key and can be a little difficult to overcome, and so I think that might be part of it.

957
02:39:14.730 --> 02:39:30.450
Renee Nygaard: And I think a way that might help is if he could provide you guys provided some very high-level scenarios that are helpful for sure um but outside of like the background user perspective, I feel like if you can provide.

958
02:39:31.470 --> 02:39:42.210
Renee Nygaard: The different scenarios with utilizing you know your system versus an outside system and how that could work in different situations, I think that would help a lot of people getting over that initial concern.

959
02:39:44.010 --> 02:39:54.180
Renee Nygaard: In particular you're starting to you definitely you know point out some of the regulatory requirements that you manifest has addressed somebody just feel like there's a couple gaps that make.

960
02:39:55.890 --> 02:39:57.210
Renee Nygaard: You make the concerns.

961
02:39:59.430 --> 02:40:03.540
Renee Nygaard: unanswered necessarily I actually posed a question during a break about that.

962
02:40:05.070 --> 02:40:10.830
Renee Nygaard: But I felt that those are a couple might be a couple of the reasons why it's been a little difficult to transition, I mean I'm a.

963
02:40:11.160 --> 02:40:22.260
Renee Nygaard: manager of 20 different EPA ids and we're remote sometimes you know some locations and so just being able to understand how it could work in the different scenarios would be helpful, thank you.

964
02:40:26.010 --> 02:40:26.580
Tess Fields: Thank you.

965
02:40:38.190 --> 02:40:41.790
Tess Fields: We have anyone else who would like to raise their hand and chime in.

966
02:40:50.760 --> 02:40:51.630
Tess Fields: we'll still have.

967
02:40:53.280 --> 02:41:03.720
Tess Fields: After Brian does the Q and A will still have one last chance if you would like to make your thoughts heard, but for the moment I will pass it over to.

968
02:41:05.070 --> 02:41:08.790
Tess Fields: To Brian to answer some of our written Q and a's.

969
02:41:09.900 --> 02:41:22.200
Bryan Groce: Excess well there aren't very many questions in the Q and A box so I'm assuming that we're doing such a great job at answering the questions during our hand raising.

970
02:41:23.310 --> 02:41:23.820
Bryan Groce: um.

971
02:41:24.900 --> 02:41:29.790
Bryan Groce: So yeah, so I think there is a general question about.

972
02:41:30.870 --> 02:41:32.220
Bryan Groce: options, three and four.

973
02:41:33.870 --> 02:41:38.580
Bryan Groce: Whether or not the generator and transporters are required to register.

974
02:41:40.170 --> 02:41:50.070
Bryan Groce: In our system and just want to confirm whether or not, because they're not registered, I wouldn't be registered, they would not have access.

975
02:41:51.540 --> 02:41:55.620
Bryan Groce: To the to the manifest in the system so.

976
02:41:56.970 --> 02:41:57.300
Bryan Groce: My.

977
02:41:59.430 --> 02:42:08.280
Bryan Groce: I believe the answer to this question, instead of secret and for wrong, at least for option for the would not be an expectation that the generator transporter.

978
02:42:09.750 --> 02:42:11.730
Bryan Groce: A registered within our manifest system.

979
02:42:13.200 --> 02:42:17.040
Bryan Groce: So, it just wants, can you confirm that, as a yes or no, or 

980
02:42:17.190 --> 02:42:18.750
Stephen Donnelly: For option for option.

981
02:42:19.200 --> 02:42:23.310
Bryan Groce: For the for the questions for scenarios.

982
02:42:25.290 --> 02:42:27.990
Bryan Groce: two and three, but I think it also applies to four as well.

983
02:42:29.400 --> 02:42:41.760
Stephen Donnelly: Alright, so two and three, so this would be talking conceptual frameworks right so yeah so for to the consideration will be at a minimum the middle of the receiving facility would be to be to be registered.

984
02:42:42.000 --> 02:42:49.980
Stephen Donnelly: Correct so yeah looks like there's no requirement for transporters or generators to be registered, other than.

985
02:42:51.210 --> 02:43:07.140
Stephen Donnelly: The benefits of having a registered user in the account for corrections or compiling aggregate reports and doing all the dude all the fun computer stuff like you know, data extracts and planning on begin system, so they would not be required to be registered and.

986
02:43:08.970 --> 02:43:13.140
Stephen Donnelly: We also so, for instance conceptual framework for free.

987
02:43:14.160 --> 02:43:18.030
Stephen Donnelly: would be someone would be required to be registered.

988
02:43:19.620 --> 02:43:21.120
Stephen Donnelly: On those on that.

989
02:43:22.470 --> 02:43:23.730
Stephen Donnelly: At every site along the way.

990
02:43:24.330 --> 02:43:26.070
Bryan Groce: and not necessarily the.

991
02:43:27.240 --> 02:43:27.870
Stephen Donnelly: person same.

992
02:43:27.900 --> 02:43:31.740
Bryan Groce: person at the dock signing and that's more to that question.

993
02:43:31.980 --> 02:43:36.000
Stephen Donnelly: yeah so, we wouldn't that you will not get that, but I would like to say in this as well.

994
02:43:37.530 --> 02:43:47.580
Stephen Donnelly: There is zero downside, and a heck of a lot of upside, whether you're doing electronic manifester not for generators and transporters to be registered and using system.

995
02:43:51.030 --> 02:43:51.990
Bryan Groce: Okay, thanks.

996
02:43:53.490 --> 02:44:02.760
Bryan Groce: So, I think they're the other two questions here that I believe these are related to the first session, and so there the question here is.

997
02:44:03.570 --> 02:44:18.450
Bryan Groce: Is there a place where EPA outlines how compliance, while the record keeping requirements are met with the manifest for each step that satisfies both guilty and waste requirements and is there a printed copy of the generated transporter sign manifest required for each truck shipment.

998
02:44:19.470 --> 02:44:22.380
Bryan Groce: So, with respect to guidance and information.

999
02:44:23.460 --> 02:44:24.630
Bryan Groce: We have a.

1000
02:44:25.740 --> 02:44:32.190
Bryan Groce: plethora of FAQs on our webpage are which addresses.

1001
02:44:33.450 --> 02:44:43.860
Bryan Groce: record keeping and just a lot of issues related to the manifest workflow in general and the system in general, so that's a good source to get information in terms of.

1002
02:44:45.240 --> 02:44:46.260
Bryan Groce: guidance on.

1003
02:44:47.610 --> 02:44:56.340
Bryan Groce: event and the clients were keeping I just want to mention, as you said previously that if you're registered in the manifest system as a generator.

1004
02:44:57.030 --> 02:45:09.780
Bryan Groce: The final copy that's ultimately submitted by the does any facility in the system or sign and ultimately submitted that if you have access, that is your copy of records paper copy and.

1005
02:45:11.250 --> 02:45:14.820
Bryan Groce: Even if it's an electronic format that would be your final copy record as well.

1006
02:45:16.080 --> 02:45:22.770
Bryan Groce: It should not register as a generator than you must have for the paper workflow you must have.

1007
02:45:23.880 --> 02:45:33.090
Bryan Groce: must receive a final signed copy from the generator and keep that copy, for your records that would apply for both that would also apply to the hybrid.

1008
02:45:34.200 --> 02:45:44.010
Bryan Groce: workflow again the hybrid manifest is a is originated in the system, but because generated doesn't have access, they receive hard copies for both their initial and final copies of the manifest.

1009
02:45:44.850 --> 02:45:53.130
Bryan Groce: And then the next question here regarding deal T unfortunately deal T currently requires that a hard copy shipping paper be.

1010
02:45:54.870 --> 02:46:08.310
Bryan Groce: accessible on the truck So even if you use the email system to track your shipments you the expectation would be that you'd have to print out a copy of that electronic manifest and keep it on your truck.

1011
02:46:10.800 --> 02:46:12.450
Bryan Groce: So, the next question here.

1012
02:46:14.940 --> 02:46:22.350
Bryan Groce: Was there's a question about who is responsible to ensure that the manifest is uploaded into the system.

1013
02:46:24.150 --> 02:46:44.580
Bryan Groce: and make a comment, saying that they are generator and their transporter pair they, as well as transporter preparing sign a paper copy of the manifests which is ultimately uploaded into the system so in the case of the case of the electronic workflow the.

1014
02:46:46.530 --> 02:47:00.570
Bryan Groce: Once the again the manifest originates in the system, and I guess trails are trails are our cat wants to generate assigns there's there's an audit trail for that to transport a science audit trail for that as well.

1015
02:47:02.040 --> 02:47:12.780
Bryan Groce: In terms of the once the receiving facility of it doesn't facility signs that final manifests on final copy and uploads in the system or his that submit button.

1016
02:47:13.350 --> 02:47:25.410
Bryan Groce: That copy, then, is uploaded into the into the system and both the generator and transporter will have access to that final copy will be in their account for viewing.

1017
02:47:27.180 --> 02:47:29.850
Bryan Groce: Scott even if you want to elaborate on that.

1018
02:47:31.170 --> 02:47:32.370
Bryan Groce: Please, please do so.

1019
02:47:40.170 --> 02:47:42.900
Stephen Donnelly: That I don't have anything to add Scotty again.

1020
02:47:45.540 --> 02:47:47.070
Scott Christian: No comments you hit it on the head again Bryan.

1021
02:47:48.240 --> 02:47:51.990
Bryan Groce: Oh, I must be I must play for the Atlanta braves great I'm.

1022
02:47:53.880 --> 02:47:56.730
Bryan Groce: not really um I think that's it for the.

1023
02:47:58.140 --> 02:48:00.630
Bryan Groce: questions in the Q amp a box thanks.

1024
02:48:06.510 --> 02:48:19.830
Tess Fields: So, this is our last slide before our how to you know stay engaged and contact us information and we just wanted to open the floor, one more time if anybody would like to.

1025
02:48:20.970 --> 02:48:23.550
Tess Fields: raise their hand and provide final feedback.

1026
02:48:27.180 --> 02:48:33.690
Tess Fields: And I will post in the chat I just put the manifests public meetings.

1027
02:48:34.980 --> 02:48:37.290
Tess Fields: website and I will also.

1028
02:48:45.270 --> 02:48:46.470
Tess Fields: Yes, Pedro.

1029
02:48:47.700 --> 02:48:49.800
Tess Fields: please feel free to unmute yourself.

1030
02:48:51.660 --> 02:48:55.770
Pedro Palomino: hi good afternoon thanks for taking my question I just put something in the chat.

1031
02:48:57.450 --> 02:49:07.560
Pedro Palomino: And then I have sort of another question when does EPA plan to replace the federal biennial reporting requirement with the E manifest system.

1032
02:49:12.780 --> 02:49:13.230
Tess Fields: Ryan.

1033
02:49:16.980 --> 02:49:17.250
Stephen Donnelly: hi.

1034
02:49:18.480 --> 02:49:19.320
Stephen Donnelly: I'm here, I'm sorry.

1035
02:49:19.590 --> 02:49:20.340
Bryan Groce: difficulty.

1036
02:49:20.550 --> 02:49:21.030
Stephen Donnelly: of writing.

1037
02:49:21.930 --> 02:49:22.920
Bryan Groce: yeah, I got it so.

1038
02:49:24.030 --> 02:49:25.020
Bryan Groce: As far as.

1039
02:49:27.120 --> 02:49:40.170
Bryan Groce: Replacing the email system, replacing the final report requirements or regulations, the manifests X says talks about the integration of the manifest system with the br.

1040
02:49:41.340 --> 02:49:46.140
Bryan Groce: So, I don't necessarily think we would ultimately replace that system, but we are currently.

1041
02:49:48.030 --> 02:49:50.070
Bryan Groce: sort of trying to work through.

1042
02:49:53.910 --> 02:50:05.850
Bryan Groce: This you know, having a sort of a conceptual approach, hopefully within our 30 manifest rule that talks about sort of our approach and how we envision that two systems might be integrate integrated.

1043
02:50:07.110 --> 02:50:18.720
Bryan Groce: that's something that's that that we continue to work with sort of evaluated and think about but that's not necessarily something that's happened in the very near- term, but I think, ultimately, our goal is to.

1044
02:50:20.040 --> 02:50:31.410
Bryan Groce: have some engagement discussion with the industry and state stakeholders to ultimately sort of finalizing approach respected the integration of manifesting vr.

1045
02:50:32.700 --> 02:50:37.260
Amanda Kohler: yeah, thanks Brian y'all I'll also add to that that uh you know, one of the.

1046
02:50:38.340 --> 02:50:44.910
Amanda Kohler: Key first steps in in reducing burden with using a manifest data for financial reporting requirements is to.

1047
02:50:45.150 --> 02:50:59.130
Amanda Kohler: is to increase adoption electronic manifest and that's because we've seen a lot of challenges, but data quality coming in, on paper manifests and so to the extent that we're able to move forward with greater adoption that will certainly help with integration with br.

1048
02:51:01.620 --> 02:51:06.630
Pedro Palomino: Thank you, man, and I think you touched on one of the issues that I've heard about.

1049
02:51:08.010 --> 02:51:10.950
Pedro Palomino: Is you know we, a I'm a large quantity generator.

1050
02:51:12.240 --> 02:51:15.210
Pedro Palomino: Work with a lot of large coin generators my company and.

1051
02:51:16.470 --> 02:51:22.290
Pedro Palomino: We send that paper manifest that Tsdfs do the data entry and our fear is.

1052
02:51:22.770 --> 02:51:30.660
Pedro Palomino: You know, we are you know we're sending thousands of manifests we're not going to be checking every single manifest and our fears there's going to be some data entry issue.

1053
02:51:31.230 --> 02:51:42.000
Pedro Palomino: From the Tsdf and then, when we go and submit our federal ban to report, you know the state agencies going to compare what's an e manifest against the Federal Court said hey, there's this there's a discrepancy here.

1054
02:51:42.900 --> 02:51:53.010
Pedro Palomino: What happened, and then we have to start trying to dig through and say was there a week a week discrepancy that we didn't check, you know, in the manifest system or.

1055
02:51:53.460 --> 02:52:01.110
Pedro Palomino: Did the key sdf the Clerk at their disposal facility just sort of miss type a number or leave a zero off a quantity.

1056
02:52:01.770 --> 02:52:12.750
Pedro Palomino: That sort of our concern I'm it and maybe you know, should we not be concerned about that and just say hey the federal port that the biennial report is the gold standard not what's in the manifest system at the moment.

1057
02:52:13.950 --> 02:52:20.520
Pedro Palomino: Like we're not being held that they need to be exactly the same, because ultimately, it's sort of two different organizations that are submitting the information.

1058
02:52:24.090 --> 02:52:30.150
Stephen Donnelly: That is that is a that is a good point Pedro, but I do want to sort of I don't want to throw out.

1059
02:52:31.410 --> 02:52:41.760
Stephen Donnelly: that's brought up a really good reason for everyone generators who registered, especially ones that El que geez and do a lot of manifests we haven't, even though the manifested by any reporting is not.

1060
02:52:42.180 --> 02:52:49.290
Stephen Donnelly: Integrated we do have the option it's been in our system since launch for receiving facilities or someone.

1061
02:52:49.290 --> 02:52:59.160
Stephen Donnelly: Using both ways posters the corrections to go into that individual waistline and add and track the vr information, so you can begin sort of doing your.

1062
02:52:59.190 --> 02:53:00.540
Stephen Donnelly: own homework for vr so.

1063
02:53:00.900 --> 02:53:05.130
Stephen Donnelly: For example, if you have a whatever particular waste code you can go in there and add a.

1064
02:53:05.580 --> 02:53:13.470
Stephen Donnelly: source and form code are all the subsequent BR information in there to sort of start building up your own library of information.

1065
02:53:13.890 --> 02:53:23.010
Stephen Donnelly: And I forget my second point oh yeah, I do remember does so states are using email address information when they're doing, they're when they're when they are.

1066
02:53:23.550 --> 02:53:32.820
Stephen Donnelly: going through the biennial reporting cycle, so they are even though it hasn't replaced BR what people are uploading and manifest, particularly the LQGs and they received facilities.

1067
02:53:34.260 --> 02:53:46.410
Stephen Donnelly: States are using that he manifests information to compare and contrast to what's being reported, so it is very much a one of the big successes of the program is for.

1068
02:53:48.060 --> 02:53:54.150
Stephen Donnelly: Helping with states in industry sort of complete their regulatory responsibility, so we do have this information.

1069
02:53:55.860 --> 02:53:58.200
Stephen Donnelly: and we look forward to working more with.

1070
02:53:58.230 --> 02:54:00.780
Pedro Palomino: yeah, and maybe I'll just add a bit of kudos is that.

1071
02:54:01.440 --> 02:54:07.980
Pedro Palomino: For anyone who's not registered in the manifest, and you can generate some nice spreadsheet reports of all your manifest out of it and that's been.

1072
02:54:08.250 --> 02:54:13.590
Pedro Palomino: I guess I sort of why I asked the question is because we've done some of that it's not adopted everywhere, but it seems like.

1073
02:54:13.920 --> 02:54:26.340
Pedro Palomino: Well, if we can do this, then, can all the state agencies and then why are we also doing the federal br, but I understand sort of processing you get everything lined up before making a big change like that so appreciate the answers.

1074
02:54:32.490 --> 02:54:33.210
Tess Fields: Great Thank you.

1075
02:54:43.260 --> 02:54:48.780
Stephen Donnelly: Brian so we have so Scott investment yeah, we have data extracts as well that for industry users to.

1076
02:54:49.260 --> 02:54:53.760
Bryan Groce: use that guy I just thank Steve I just want to mention that there was another question.

1077
02:54:57.060 --> 02:55:00.030
Bryan Groce: came about, so the question here is.

1078
02:55:01.260 --> 02:55:07.380
Bryan Groce: The questionnaires that are generated has multiple sites, do they need to have.

1079
02:55:08.670 --> 02:55:23.130
Bryan Groce: Do they need to register each site and refer info or have one site manager would need to have one site manager for each site are can they have one time manage for all the generator sites our recommendation is that.

1080
02:55:24.300 --> 02:55:27.480
Bryan Groce: Each site has at least one site manager.

1081
02:55:28.620 --> 02:55:45.840
Bryan Groce: So, as opposed to having one for all the generators are generated size, regardless of the waste handler type whether the generated transporter or doesn't facility a recommendation is that each site have one site manager.

1082
02:55:50.970 --> 02:55:51.570
Bryan Groce: it's already had.

1083
02:55:53.850 --> 02:55:55.440
Scott Christian: At least one site manager.

1084
02:55:55.830 --> 02:56:01.470
Scott Christian: yeah, you really want to have some redundancy there so that, if one site manager leaves.

1085
02:56:02.520 --> 02:56:04.380
Scott Christian: We do have site managers for lots of sites.

1086
02:56:07.980 --> 02:56:10.860
Scott Christian: what's the record Steve you know, really.

1087
02:56:10.890 --> 02:56:11.520
Healthy said.

1088
02:56:13.110 --> 02:56:15.660
Stephen Donnelly: it's couple thousands like for the lot of the corporate.

1089
02:56:16.230 --> 02:56:28.080
Stephen Donnelly: stores box stores, they have a lot of statement yeah, they'll break it up with a lot of sites, but yeah and we have ways of doing it, so you have a site manager and then the people that are on site at the generator say can have view access so.

1090
02:56:28.530 --> 02:56:36.330
Stephen Donnelly: inspector comes they can go view all the manifests and print them out for the specter and go about their business.

1091
02:56:58.770 --> 02:57:04.590
Tess Fields: um I would just like to read a comment that was put in the chat by Larry.

1092
02:57:05.160 --> 02:57:11.160
Tess Fields: I think it would be helpful, this is this comment, I think it would be helpful for EPA to shout it from the rooftops that generators.

1093
02:57:11.520 --> 02:57:21.330
Tess Fields: should be making sure that the information in a manifest is correct, because not only are States comparing data when it comes to biennial reporting, but state regulators are already looking at.

1094
02:57:21.720 --> 02:57:28.530
Tess Fields: generators data in a manifest so if it is wrong, the state is looking at wrong information, so thank you for that come on.

1095
02:57:32.850 --> 02:57:33.870
Amanda Kohler: Get on the roof Steve.

1096
02:57:35.460 --> 02:57:38.250
Stephen Donnelly: I've actually violates one of our ground rules of the meeting so.

1097
02:57:40.920 --> 02:57:41.820
Amanda Kohler: Safety first.

1098
02:57:42.030 --> 02:57:42.750
Amanda Kohler: yeah, first you.

1099
02:57:47.580 --> 02:57:51.150
Stephen Donnelly: know and also so when you consider other potential options.

1100
02:57:52.200 --> 02:58:03.120
Stephen Donnelly: It doesn't we're not asking for everyone to propose a solution, but if you do want to put into the docket something about your considerations, we should have especially with transport, so no barges or.

1101
02:58:04.080 --> 02:58:13.110
Stephen Donnelly: Mixed rail systems and of course the multiple transporters so yeah, let us know all your thoughts on electronic signatures, you want to hear you.

1102
02:58:24.600 --> 02:58:25.170
Tess Fields: Have any.

1103
02:58:29.010 --> 02:58:30.090
Tess Fields: final thoughts.

1104
02:58:32.670 --> 02:58:36.630
Tess Fields: David has pointed out that there's another comment in the.

1105
02:58:39.300 --> 02:58:51.930
Tess Fields: Q and A box Maria says, I agree with Larry this was what was initiated this is what initiated my earlier question because we are a large quantity generator, and he manifests has only three manifests uploaded.

1106
02:58:54.210 --> 02:59:09.930
Tess Fields: And then there was another comment that said as a hazardous waste generator we would support adopting he manifest for our wastes if our hazardous waste broker transporter was on board if they are not fully adopting the manifest system, we will follow their lead.

1107
02:59:11.790 --> 02:59:13.020
Tess Fields: Thank you for that comment as well.

1108
02:59:28.590 --> 02:59:31.920
Tess Fields: Are there any other final comments I'm.

1109
02:59:33.900 --> 02:59:38.880
Tess Fields: A reminder to also Please submit any written comments in the docket we're accepting.

1110
02:59:40.200 --> 02:59:44.610
Tess Fields: written comments through December 30 of this year.

1111
02:59:45.690 --> 02:59:48.660
Tess Fields: And you can do that by commenting on the Federal Register notice.

1112
02:59:51.300 --> 02:59:53.760
Tess Fields: In the docket that I put in the chat.

1113
02:59:55.140 --> 02:59:58.230
Stephen Donnelly: spend your holiday season thinking about.

1114
02:59:59.550 --> 03:00:01.890
Stephen Donnelly: Other potential options for electronic signatures.

1115
03:00:11.190 --> 03:00:14.040
Tess Fields: right with that I think Steve you can.

1116
03:00:15.780 --> 03:00:16.350
Tess Fields: Take us on.

1117
03:00:19.320 --> 03:00:28.890
Stephen Donnelly: All right, yeah so, it's a as we wrap this thing up the Federal Register notice is open for public comment until December 30 and then we have.

1118
03:00:30.360 --> 03:00:43.320
Stephen Donnelly: All of our materials are going to be up there on the web, and we are going to use this information and all the information from our any additional sessions and the stuff you put into the docket to.

1119
03:00:44.490 --> 03:00:55.170
Stephen Donnelly: inform options for consideration, but he manifests advisory board, and of course we're going to get our information out in the public before that, so you'll have ample opportunity to review comment on those and.

1120
03:00:55.920 --> 03:01:05.490
Stephen Donnelly: Now, so the sort of big the hard sell here we need and rely on an engaged and active stakeholder.

1121
03:01:07.320 --> 03:01:09.630
Stephen Donnelly: Community so that is.

1122
03:01:10.830 --> 03:01:24.840
Stephen Donnelly: that's my pitch and also reminder the appendix it's great it's wonderful stuff so thank you all for attending Thank you all for being a part of the manifest can you believe it's been more than three years and.

1123
03:01:26.220 --> 03:01:31.800
Stephen Donnelly: it's been quite a ride all right, and thank you very much, and remember here is the useful links, if you.

1124
03:01:32.190 --> 03:01:36.300
Stephen Donnelly: You have any questions check the FAQs someone's probably ask them before and.

1125
03:01:36.660 --> 03:01:45.630
Stephen Donnelly: The program website has got all the great things you need and the github repository is got everything else you need from the it side, give us a call give us an email, and we will.

1126
03:01:46.020 --> 03:01:58.590
Stephen Donnelly: See you soon Thank you again, and thank you to the manifest team, especially and you do the Amanda, Brian, Tess, William Scott, Thomas.

1127
03:01:59.970 --> 03:02:03.630
Stephen Donnelly: David there's the other David and there's a.

1128
03:02:04.170 --> 03:02:05.040
Amanda Kohler: Done miss one.

1129
03:02:07.860 --> 03:02:13.680
Stephen Donnelly: Here there's a lot of people Thomas, Kesha. Marian, Laura Tammie, Tamue. Thank you to everybody.

1130
03:02:14.820 --> 03:02:23.160
Stephen Donnelly: I think I got everyone. If not, I will submit comments to the docket Thank you very much, I will end this meeting now.

