With the goal of improving…

With the goal of improving efficiency and compliance for both industry and MECP alike, please consider the following comments which are based on lessons learned by our organization from experience working on a similar digitization project with regulatory authorities in the field of hazardous waste

While agreeing to the objective of requiring all manifest data be entered electronically into
the MECP electronic database at the (end of the shipment), The details of accomplishing this are important.

Please consider the suggested 3 ways that this can be accomplished (in order of least preferred to most preferred):
1) Paper Copy mailed to the MECP affiliated administration center (least preferred, but this option should still remain as a backup in case of connectivity and other technical issues)
2) Provide a Scanned Manifest into the MECP system (which should have character recognition technology)
3) Enable the MECP affiliated system to accept a data transfer containing required manifest data from existing Industry "business machines" (systems) through a Data Portal. (This is the most efficient) This data transfer arrangement has been enabled by the US EPA and represents the most efficient way as it reduces the redundant data entry burden caused by re-keying all data in a parallel MECP system. For companies that do not have this capability in their current systems, the MECP system should be used to enter data. However, companies with existing systems should have the ability to "talk" to the MECP system and transfer the required data fields. Details of how this could be accomplished needs to be explored when selecting the "business machine" platform that is to be used by the MECP/RPRA

Requiring the entry of shipment data from the point of shipment into the MECP system is very burdensome and represents an increase in complications for both the generators and hazwaste companies and should be an option but NOT a requirement. We feel strongly that this will be very problematic on many levels if it becomes a compliance rule. The focus should be data transfer at the end of the shipment (while ensuring proper generator registration).

In regards to the topic of registering specific waste classes prior to the shipment, removing the need to register these into the generator account should be explored (It is currently a requirement with HWIN). If the data is being uploaded at the end of the shipment, and the generator has an active registration number, why should there be a need to register specific waste classes? The alternative is to leave an "open" profile and ship whatever waste classes are needed, while retaining the ability to review historical waste class shipments with the ability to print out an LDR report from the system. (The LDR report could be printed either from the MECP system, or another system as long as it complies with the report requirements) We believe removing the requirement to register waste classes under the generator account will improve efficiency without affecting compliance.

Thank you for the opportunity to comment.