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

WEBVTT

1 00:01:14.190 --> 00:01:22.920 Stephen Donnelly: Alright, good afternoon and welcome everybody to the first of our electronic.

2 00:01:23.520 --> 00:01:39.300 Stephen Donnelly: meetings on increasing electronic adoption attract manifests Thank you very much, please note that the recording and transcription has now started, and we will post these in the docket as soon as we are able to.

3 00:01:40.410 --> 00:01:49.440 Stephen Donnelly: And let's get things kicked off with a few opening remarks from the division director of the.

4 00:01:50.700 --> 00:01:58.470 Stephen Donnelly: program information and implementation division sorry implementation information division that's so nice, so thank you very much so.

5 00:02:03.630 --> 00:02:18.000 Sonya Sasseville: All right, good afternoon, everyone and Steve I'm not surprised that you would put information first being doing what you do, but anyways good afternoon, everybody, welcome to the manifest virtual public meeting.

6 00:02:19.110 --> 00:02:24.330 Sonya Sasseville: on increasing adoption of electronic manifests, thank you for joining us today.

7 00:02:25.140 --> 00:02:35.880 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.

8 00:02:36.450 --> 00:02:44.040 Sonya Sasseville: widespread adoption of electronic manifests is how we will truly unleash the benefits of a manifest including.

9 00:02:44.520 --> 00:03:05.040 Sonya Sasseville: maximizing cost savings and burden reduction, improving the quality of manifest data integrating manifests with the bi-Annual Report requirements and enhancing monitoring of hazardous waste shipments nationwide so we're at an exciting time for a manifest since launching.

10 00:03:06.240 --> 00:03:27.150 Sonya Sasseville: In 18 we work together to lay the foundation of our program EPA spend time by way of several manifest advisory board meetings and other feedback than us learning the needs and challenges of our stakeholders with respect to a lot electronic manifesting and we're trying to.

11 00:03:28.380 --> 00:03:38.820 Sonya Sasseville: address them so in 2020 was concurrence from the E manifest advisory board we updated our policy with respect to electronic signatures for.

12 00:03:39.240 --> 00:03:52.530 Sonya Sasseville: generators transporters and initial signatures by receiving facilities and we implemented the new quick sign feature quick sign was a dramatic improvement to our electronic manifesting process.

13 00:03:53.250 --> 00:04:02.310 Sonya Sasseville: However, we know that this isn't enough electronic manifests still represent just about a half a percent of the total manifest volume.

14 00:04:02.700 --> 00:04:16.860 Sonya Sasseville: So definitely that's not where we want to be in 2021, we committed to the manifest Advisory Board to explore other potential solutions to increase electronic manifest adoption among users.

15 00:04:17.460 --> 00:04:30.180 Sonya Sasseville: Which brings us to today's public meeting our objective today is to get early input from you that we can use in defining potential options for future consideration by the manifest Advisory Board.

16 00:04:30.930 --> 00:04:43.560 Sonya Sasseville: What you hear today by no means represents formal proposals or concrete plans by the Agency, we are at the idea stage and your input will be very valuable to shaping where we go next.

17 00:04:45.540 --> 00:04:57.600 Sonya Sasseville: As we go through this process, I encourage you to keep an open mind and embrace changes that may relate to your own current practices and systems in moving toward electronic manifest.

18 00:04:58.500 --> 00:05:13.320 Sonya Sasseville: We have always taken pride in this program in the fact that your manifest successes and shared success among our users among state and EPA regional partners and, among others, that use and derive value from the data.

19 00:05:13.890 --> 00:05:20.580 Sonya Sasseville: So, I encourage us all to continue working together to make this next bleep possible with that.

20 00:05:21.390 --> 00:05:35.610 Sonya Sasseville: I know that the manifest team is ready to begin presenting and eager to listen to learn from our stakeholders, I look forward to seeing the outcome of our time together. Thank you again and I'll turn it back over to Steve.

21 00:05:39.870 --> 00:05:46.770 Stephen Donnelly: All right, thank you, Sonya we have an action-packed agenda and if you.

22 00:05:47.580 --> 00:05:55.170 Stephen Donnelly: want to know what's going on, so yeah so for the first part of the meeting we're going to lay out our objectives as a background and we're and we're going to go through our current.

23 00:05:55.500 --> 00:06:08.220 Stephen Donnelly: manifest workflow we want to get everybody sort of a ground sort of ground truth, a lot of the basic workings of the current system before we can move on, we have a break at 2:50pm over.

24 00:06:09.270 --> 00:06:28.170 Stephen Donnelly: Where we're going to collect our thoughts and then we'll get into a policy discussion and talk about some EPA signature policy, as well as proposed options and go to the Statute regulations, and then we will adjourn and do remember that this is a.

25 00:06:29.310 --> 00:06:35.850 Stephen Donnelly: This is, first of a public meeting of our electronic  adoption and public meetings we're going to do more.

26 00:06:36.420 --> 00:06:50.130 Stephen Donnelly: we're going to have another session next week and then, if there is a desire and there's a need to be able to do more things all right, well, thank you very much I'm going to pass this along to David Graham.

27 00:06:54.840 --> 00:07:00.480 David Graham: All right, thank you Steve before we get started, I know everyone's excited.

28 00:07:01.590 --> 00:07:09.720 David Graham: and eager to start talking about electronic manifests a few housekeeping items, so please keep yourself muted throughout meeting.

29 00:07:11.010 --> 00:07:14.070 David Graham: In fact, since we're using zoom it's going to be.

30 00:07:15.630 --> 00:07:27.240 David Graham: very difficult for you to unmute yourself unless we ask you to. If you'd like to comment during the discussion periods, please use the raise your hand button and then we'll ask you to unmute yourself.

31 00:07:29.250 --> 00:07:45.240 David Graham: You can put questions in the Q and Abox, the entire time that we're presenting, and we'll try to address them and timely manner and those that we can't get to today will try to get or those we can get to immediately will try to get to at the end of the session.

32 00:07:47.790 --> 00:08:03.240 David Graham: Also note that the proposed agenda times that Steve just outlined are approximate we may end a little early if one of the Q and A sessions doesn't last long comments you know presentations don't take as long So those are approximate time, so we encourage you to stay tuned.

33 00:08:05.340 --> 00:08:15.630 David Graham: And also, please note that this meeting is being recorded, and the recording as well as the transcript will be posted in the public docket which will share a link with you here in a moment.

34 00:08:17.670 --> 00:08:24.600 David Graham: Please note you can also submit any written comments to the d docket until December 30 so it's open for a limited time.

35 00:08:25.620 --> 00:08:25.920

36 00:08:31.500 --> 00:08:33.780 David Graham: With that I'm going to pass it back over to Steve.

37 00:08:36.180 --> 00:08:49.590 Stephen Donnelly: Oh, right Thank you Thank you again so let's go through our meeting objectives and background, so this is, I hope we all know why we're here, but in case we go let's go let's go to the next slide and see where we are.

38 00:08:50.790 --> 00:08:52.380 Stephen Donnelly: So, the manifest.

39 00:08:54.480 --> 00:09:03.540 Stephen Donnelly: To achieve the at the objectives of the hazardous waste electronic manifest establishment and or as we like to call the manifest act includes decreasing birth.

40 00:09:04.080 --> 00:09:12.480 Stephen Donnelly: And the only way we can decrease burden and achieve integration with by not reporting and really move this program forward is to.

41 00:09:13.380 --> 00:09:27.150 Stephen Donnelly: have wide adoption of electronic so we get somewhere in the neighborhood of 2 million manifest per year and it currently represents less than 1%, so we are, we are in, we are in.

42 00:09:28.410 --> 00:09:30.510 Stephen Donnelly: We are looking forward to getting some more manifester.

43 00:09:31.560 --> 00:09:49.980 Stephen Donnelly: And we understand that we're not getting a lot, and this is far, far short of the expectations -- industry expectations and state expectations of where we should be after three years of operation, when it comes to adopting electronic methods.

44 00:09:53.310 --> 00:10:04.920 Stephen Donnelly: So, we can go to the next slide, so This brings us to these meetings, so the purpose here is to get your individual feedback and ideas and ways to increase adoption of electronic manifests.

45 00:10:05.400 --> 00:10:16.710 Stephen Donnelly: We are going to use this information to develop further options for the Advisory Board to consider in a public meeting we're planning for the county or 2022.

46 00:10:17.850 --> 00:10:28.350 Stephen Donnelly: And in addition to that sort of thinking about the future, we want to think about where we are in the present, so another objective of this meeting in a very good one, is to.

47 00:10:29.220 --> 00:10:42.990 Stephen Donnelly: get a sort of inform and educate our stakeholders, particularly on the industry side, about the use of our current electronic workflow particularly how it can be used by a service.

48 00:10:44.040 --> 00:10:49.710 Stephen Donnelly: By building on what we see a lot of for data plus image, so we have an in place.

49 00:10:50.970 --> 00:11:00.390 Stephen Donnelly: Where methodology of receiving data from our industry systems that is widely roughly 80% to 85% of the manifest data coming in, is through our services.

50 00:11:00.810 --> 00:11:13.080 Stephen Donnelly: And we can also do the electronic workflow much of it through our services, so we want to be able to increase understanding and use of our current workflow so that will help us in two weeks we'll be able to.

51 00:11:14.430 --> 00:11:28.440 Stephen Donnelly: Potentially see an increase in electronic debt adoption on our as his system, and if there are further options for the Advisory Board to consider and we have a robust back and forth conversation.

52 00:11:29.490 --> 00:11:35.640 Stephen Donnelly: In the series of meetings and through public commenting we will be able to have a better educated.

53 00:11:37.050 --> 00:11:45.180 Stephen Donnelly: stakeholder Community proposing options, seeing as they now know how exactly how the current system works.

54 00:11:47.370 --> 00:11:50.670 Stephen Donnelly: So, we're going to get everybody on this on the same page.

55 00:11:51.090 --> 00:11:58.410 Stephen Donnelly: All right, and then as well we're going to be  hitting this a lot, but all the materials for these meetings are going to be going on to our public docket.

56 00:11:58.740 --> 00:12:11.820 Stephen Donnelly: And we will be accepting written comments until December 30, 2021, so just about until the end of the year, so please, if you have a question or an idea and it doesn't get covered, or if it's sort of.

57 00:12:12.450 --> 00:12:19.920 Stephen Donnelly: not fully developed yet, and you don't feel like sharing it in the Q&A box or raising your hand, please, where are.

58 00:12:20.610 --> 00:12:34.110 Stephen Donnelly: We are imploring you to make your feelings heard in the in the public the public docker so we can consider those, and we'll have you guys considered public, so please, please, please, please go into the docket.

59 00:12:40.500 --> 00:12:52.890 David Graham: Alright, so a couple more logistical items to take care of before we really kicked this meeting off, is that this is not a federal advisory committee meeting or not a FACA meeting.

60 00:12:53.490 --> 00:13:04.800 David Graham: Right so, as such, we need to ensure that we abide by certain procedures right, and this perfect I should say generally applies to groups that EPA establishes to utilize.

61 00:13:06.090 --> 00:13:12.990 David Graham: an interest in obtaining group advice and recommendations right, so we take our factor responsibilities very seriously and,

62 00:13:14.760 --> 00:13:22.440 David Graham: at the same time, we also to we're also seeking input from individuals outside of the FACA process and entities.

63 00:13:24.090 --> 00:13:25.950 David Graham: not subject to FACA right I'm.

64 00:13:28.050 --> 00:13:30.960 David Graham: Sorry, so the takeaway here is that.

65 00:13:32.070 --> 00:13:35.820 David Graham: We are seeking individual input not collective advice today right.

66 00:13:36.240 --> 00:13:46.170 David Graham: So, if an organization sends a representative to more than one meeting that's considered to be the same individual attending, even if the organizational sends different individuals to the meeting.

67 00:13:46.830 --> 00:13:57.090 David Graham: Additionally, if an organization and sends two or more people to the same meeting, they are still providing individual input from one organization.

68 00:13:58.080 --> 00:14:09.030 David Graham: So, during today's discussion and during those Q and A sessions, we welcome discussion, but we ask that you direct your comments to EPA not towards each other.

69 00:14:13.770 --> 00:14:22.410 David Graham: In addition to directing your comments towards the EPA this meeting is solely focused on increasing the adoption of electronic manifest.

70 00:14:23.130 --> 00:14:29.670 David Graham: And as such we're going to try to steer this conversation away from their hot topics, you know we e-Manifest is.

71 00:14:30.390 --> 00:14:43.290 David Graham: Is multifaceted but today we're going to try to stay away from data quality, paper manifest concerns, waste determinations, user fees, as well as even the third rule making right so.

72 00:14:44.700 --> 00:14:48.240 David Graham: Thank you very much for your help and giving us a.

73 00:14:49.350 --> 00:14:53.940 David Graham:  focused conversation today now with that I'm going to turn it back over to Steve.

74 00:14:57.630 --> 00:15:12.720 Stephen Donnelly: Okay, thanks, David I so let's do a brief history of the manifests and electronic signature, so this is not the entire history, this goes back to well before June 2019, but this is sort of where things get interesting.

75 00:15:13.920 --> 00:15:34.440 Stephen Donnelly: As far as you know, bringing us all together so in June 2019 we had an advisory board meeting specifically requesting information to understand from our users, the barriers to using electronic methods and actions, we could take to enhance the widespread enhance adoption.

76 00:15:35.940 --> 00:15:51.540 Stephen Donnelly: We propose some items we had we had great back and forth via some great public commenters and in September 2019 after we receive the advisory board's recommendation, they asked the Agency to reconsider whether.

77 00:15:53.400 --> 00:15:59.940 Stephen Donnelly: All users need to adhere to the existing registration process and consider changing.

78 00:16:00.450 --> 00:16:11.280 Stephen Donnelly: Changing or eliminating the Cross media electronic reporting rule requirement for transactions prior to receipt as well as reevaluate.

79 00:16:12.030 --> 00:16:22.410 Stephen Donnelly: Signature requirements in general, so essentially the feeling from the Advisory Board was please take a look at the laws governing your electronic signatures and.

80 00:16:23.700 --> 00:16:28.170 Stephen Donnelly: report back to us, so we did so we can go to the next slide.

81 00:16:31.590 --> 00:16:42.390 Stephen Donnelly: All right, alright, so we followed on the board's recommendation so for those of you in who remember April 2020 This was our first electronic our first virtual.

82 00:16:43.740 --> 00:16:53.730 Stephen Donnelly: Public meeting or online public meeting, there is no in person, it was April 2020 and big thanks to the team for pulling that, all together, that was a lot of a lot of fun stuff.

83 00:16:55.560 --> 00:17:02.040 Stephen Donnelly: Behind the behind the curtain to get that going we proposed additional methods for increasing the use of electronic manifest.

84 00:17:03.240 --> 00:17:12.930 Stephen Donnelly: This included re-engineering signatures for the generator transporters to reduce the burden and barriers to electronic manifest essentially.

85 00:17:13.320 --> 00:17:33.600 Stephen Donnelly: We proposed among several items essentially removing the CROMERR requirement from non-final signatures of a manifest so this could be a this could be for your final so a generator transporter initial receipt and then chromium requirements would win for me and for the.

86 00:17:34.650 --> 00:17:48.240 Stephen Donnelly: Any final signatures are correct, and we propose that and then July we received concurrence that removing those requirements for non-final signature is the manifest was a good idea and.

87 00:17:49.200 --> 00:18:00.750 Stephen Donnelly: Also, you can we receive recommendations to continue to work to integrate a manifest with industry systems by data services by using a PS.

88 00:18:04.140 --> 00:18:07.380 Stephen Donnelly: Alright, so wow it's October 2020.

89 00:18:08.460 --> 00:18:17.460 Stephen Donnelly: Okay, so it's a year ago, so we responded to the advisory board's recommendations confirming that the chromium requirements apply only to.

90 00:18:18.720 --> 00:18:22.200 Stephen Donnelly: Final signature of the manifest or post received corrections.

91 00:18:23.220 --> 00:18:26.040 Stephen Donnelly: And they will not apply to any non-final.

92 00:18:27.360 --> 00:18:41.220 Stephen Donnelly: And we also said, we will continue to work with our stakeholders to explore solutions that will lower barriers to lower barriers of entry or industry, so they can do or electronic manifests, as we all want.

93 00:18:42.600 --> 00:18:46.260 Stephen Donnelly: And also, this is a big thing in December 2020.

94 00:18:47.340 --> 00:19:04.500 Stephen Donnelly: We deploy the new quick sign functionality, which has been used where a non-final signature can be signed by anyone who has access to a site that is not viewer, and they can just click a button that says click sign and then manifest is science.

95 00:19:06.000 --> 00:19:14.850 Stephen Donnelly: To the wild come up with that name, but we do, we have seen a slight increase electronic manifest since quick sign has been deployed.

96 00:19:17.970 --> 00:19:21.510 Stephen Donnelly: All right, in March 2021 just a few months ago.

97 00:19:22.530 --> 00:19:26.640 Stephen Donnelly: We had an advisory board meeting to.

98 00:19:28.500 --> 00:19:38.370 Stephen Donnelly: To work through our program priorities and associated user fees for the fyi 2223 fee cycle and a key priority of that.

99 00:19:39.090 --> 00:19:51.630 Stephen Donnelly: Of the work and that cycle was to is to since we're in it now is direct engagement with stakeholders to increase electronic manifest submissions one of the reasons, we're here and.

100 00:19:52.740 --> 00:19:57.810 Stephen Donnelly: We also and then in May we receive our recommendations from the Advisory Board.

101 00:19:58.920 --> 00:20:08.310 Stephen Donnelly: that the agency address lack of industry, adoption and to integrate with our hazardous waste industries private systems.

102 00:20:08.790 --> 00:20:19.230 Stephen Donnelly: With the math so you've heard this before we heard it again very strongly that they wanted that people want direct engagement to increase electronic manifest and.

103 00:20:20.340 --> 00:20:25.890 Stephen Donnelly: sort of how that will happen is with the e-manifest system and industry systems talking to each other.

104 00:20:27.900 --> 00:20:30.900 Stephen Donnelly: and June 2021 just a few months ago.

105 00:20:31.920 --> 00:20:40.620 Stephen Donnelly: And our and our responses Advisory Board, where we finalized our user fees, we also committed to holding public meetings later in 2021.

106 00:20:40.950 --> 00:20:50.610 Stephen Donnelly: To discuss potential options for improving the use of electronic manifests which is it is why, which is why we're here so.

107 00:20:51.420 --> 00:20:59.430 Stephen Donnelly: This was a as a brief history of the background of this issue, essentially be heard, for a very long time that people industry once.

108 00:20:59.820 --> 00:21:07.080 Stephen Donnelly: More integration with the e-manifest system and that will get us more electronic manifests, so now we are here.

109 00:21:08.010 --> 00:21:14.610 Stephen Donnelly: To discuss that and it's going to get a little bit technical because you know we've  gotten past the broad strokes of.

110 00:21:15.240 --> 00:21:29.730 Stephen Donnelly: Okay, we want to integrate Well, now we have we have the Y or that but now we have to do the House so it's going to get a little tactical on the policy side it's going to be a lot tactical on the it side, but ultimately, we feel this will be really productive conversation so.

111 00:21:30.930 --> 00:21:37.800 Stephen Donnelly: To take it away, I will pass the baton off to the manifest technical lead Scott Christian.

112 00:21:40.680 --> 00:21:41.790 Scott Christian: Thank you Steve.

113 00:21:43.710 --> 00:21:45.930 Scott Christian: All right, the current electronic manifest workflow.

114 00:21:48.150 --> 00:21:56.130 Scott Christian: Please next slide so this section we're going to go through the current electronic manifest workflow, with the focus on services.

115 00:21:57.840 --> 00:22:09.240 Scott Christian: Looking at the attendee list pretty much everyone has seen what the Web user interface version of our electronic manifesting has.

116 00:22:09.960 --> 00:22:17.700 Scott Christian: gone through, if not, these are recorded we've gone through them a lot of times, so we're going to delve in deeper into services.

117 00:22:18.540 --> 00:22:35.610 Scott Christian: Then we're going to take you through the API's as they relate to the full electronic workflow in the hybrid workflow to go deep into each step that you can see it and so you can repeat it, and finally be handing the

118 00:22:36.660 --> 00:22:42.120 Scott Christian: baton over to William Nicholas who developed a DEMO using the Python language.

119 00:22:43.350 --> 00:22:55.560 Scott Christian: Using those previous two scenarios that I had at the  described. David please go to the next slide. This slide sets our expectations and explanations for this section.

120 00:22:57.180 --> 00:23:05.820 Scott Christian: This section is going to be technical we're trying to show you how easy it is for your systems to talk to the manifest and we're going to do our best to explain.

121 00:23:06.900 --> 00:23:16.320 Scott Christian: What this isn't how it is, but if you're not an IT person, please stay and  pay attention take notes and be sure to share this recording with the appropriate IT staff.

122 00:23:17.610 --> 00:23:26.430 Scott Christian: We want you all to have those conversations internally as well, and if you use a third-party system, please share with your third-party system with contractors.

123 00:23:28.320 --> 00:23:37.170 Scott Christian: we're also providing you examples, step by step, so that your IT staff can recreate this DEMO in your own tools and systems.

124 00:23:38.010 --> 00:23:47.190 Scott Christian:  I'll get to that a little bit later, and please contact us with questions.   The reason I put contact us and double quotes is because we have a contact us slide at the end.

125 00:23:47.550 --> 00:24:00.480 Scott Christian: And since we're trying to get things in the docket and create this conversation that everybody on the team can see please use that contact us and, yes, as many of you are familiar, were very receptive to answering questions about.

126 00:24:01.680 --> 00:24:05.280 Scott Christian: API's recently went through a big, long.

127 00:24:08.940 --> 00:24:09.510 Scott Christian: With.

128 00:24:10.530 --> 00:24:20.160 Scott Christian: Helping a bunch of sites move from mail to image plus data and fully electronic manifesting using services and the Web APP.

129 00:24:22.140 --> 00:24:28.770 Scott Christian: we're experienced and helping folks get to that goal, we  definitely want you to ask questions, and please ask them to the contact us.

130 00:24:30.180 --> 00:24:41.310 Scott Christian: I'm going to take the process slow at the beginning part when I'm explaining each step, because when Williams takes over it shows the DEMO it's going to go pretty fast, just like your transactions do today.

131 00:24:42.510 --> 00:24:47.220 Scott Christian: So, and biggest caveat and William will.

132 00:24:48.570 --> 00:24:54.570 Scott Christian: put this caveat at the end as well we're trying to show you options, there are a lot of ways to use web services, as you will see.

133 00:24:56.700 --> 00:25:08.460 Scott Christian: find the ways that work best with your systems and another reason why we're doing this section 85% of our manifest comm system, so this is where

134 00:25:09.540 --> 00:25:13.320 Scott Christian: the bulk of the manifests are coming from.

135 00:25:16.050 --> 00:25:18.750 Scott Christian: let's leverage that next slide please.

136 00:25:20.340 --> 00:25:24.540 Scott Christian: So, I'm going to dive in and ask you to explain you what is a rest API.

137 00:25:26.220 --> 00:25:39.120 Scott Christian: And this is our system, the system infrastructure, before we even get to rest is what is an API, an API is an application programming interface it's a  how systems talk to each other.

138 00:25:40.200 --> 00:25:48.360 Scott Christian: Similar a user to a user interface in the APP, with an API one system sends a request the other one response to that request.

139 00:25:49.410 --> 00:25:55.830 Scott Christian: Rest API's are a type of API they stand for Representational State Transfer.

140 00:25:56.850 --> 00:26:04.920 Scott Christian: API and that PhD computer science speak for basically you're taking something.

141 00:26:06.300 --> 00:26:13.560 Scott Christian: And you're sending a representation of that in the state that it was in at the time.

142 00:26:14.760 --> 00:26:35.790 Scott Christian: It was requested to another application. My favorite example on explaining this is the Mona Lisa pretty much everybody on this call today has seen the Mona Lisa a representation of Mona Lisa some of them seen the real thing but everybody has seen a representation of the Mona Lisa.

143 00:26:36.960 --> 00:26:48.120 Scott Christian: At the time, that that image was taken and let's say the Louvre in their infinite wisdom decides, they want to do something to the Mona Lisa to make it last another 500 years.

144 00:26:49.140 --> 00:26:49.890 Scott Christian: and

145 00:26:52.770 --> 00:26:55.050 Scott Christian: They do their

146 00:26:56.310 --> 00:27:03.750 Scott Christian: magical stuff that they need to do, and now there's a new representation of the Mona Lisa that will last another 500 years.

147 00:27:06.210 --> 00:27:07.200 Scott Christian: we've all seen the manifest.

148 00:27:08.580 --> 00:27:12.900 Scott Christian:  representation from before, and now the new representation, we will see.

149 00:27:14.430 --> 00:27:14.970 Scott Christian:

150 00:27:17.370 --> 00:27:29.790 Scott Christian: The hopefully that figures that that that helps another reason we use this is because think about the manifest representation of the manifest the generator sees.

151 00:27:30.450 --> 00:27:43.920 Scott Christian: Is one representation, they sign it, the transport a sees another representation of that manifest then they sign it, and finally the TSDF sees that representation of that manifest when they sign it with all the signatures on.

152 00:27:44.910 --> 00:27:51.960 Scott Christian: So, the manifest changes throughout and the API's are shooting manifests up and down accordingly.

153 00:27:53.460 --> 00:28:03.750 Scott Christian: great thing about rest is it's well understood by developers globally it's pretty much how the Internet talks chances are you're probably using ReST API's to watch this.

154 00:28:04.170 --> 00:28:11.160 Scott Christian: Presentation we're on teams, I would say, you were but I haven't checked out zoom's back-end chances are they're using rest as well.

155 00:28:12.840 --> 00:28:21.300 Scott Christian: So, it's there they're everywhere lot of people know how to use it and the more talent, to the ups and downs of systems sure how the next slide.

156 00:28:23.250 --> 00:28:37.560 Scott Christian: So, wanted to kind of reiterate the point and show an image or a couple slides reporting kind of a bigger detail user provides a username and password in the system, except for credentials and creates a login.

157 00:28:38.640 --> 00:28:48.000 Scott Christian: Industry system provides an API and key and accepts credentials and creates an API session so.

158 00:28:49.860 --> 00:28:54.510 Scott Christian: yeah it's kind of in a nutshell, how API's were, sends a request sends back a response.

159 00:28:55.680 --> 00:28:56.430 Scott Christian: For the next slide.

160 00:28:57.780 --> 00:29:04.590 Scott Christian: So now we know that they send responsible, how do they communicate well how do we know what that request is and what that responses.

161 00:29:05.850 --> 00:29:11.220 Scott Christian: In our we use JavaScript object notation there's other.

162 00:29:12.360 --> 00:29:21.270 Scott Christian: file formats out there, that people use yeah xml but json is basically it's a text file with predictable format.

163 00:29:23.040 --> 00:29:26.640 Scott Christian: And it allows in a repeatable.

164 00:29:28.920 --> 00:29:39.030 Scott Christian: Reliable wait for one system to send a request and tell the other system what they're doing, and then the other system to send a response back.

165 00:29:39.810 --> 00:29:55.320 Scott Christian: json consists of a key and a value pair, the key is what identifies what you're trying to convey, so the example I have here is printed DOT information is the key so on every manifest that has a hazardous material on it.

166 00:29:56.340 --> 00:30:06.150 Scott Christian: There is a printed DOT information key on each waste line and then there's about a pair which is going to be different for pretty much every manifest.

167 00:30:07.590 --> 00:30:12.900 Scott Christian: In this case, it's NA1993 waste diesel fuel as a Class three packing group three.

168 00:30:14.700 --> 00:30:20.460 Scott Christian: So, with that you can kind of see an example and on the next slide we have a map.

169 00:30:21.570 --> 00:30:30.660 Scott Christian: So, you look at the bottom of the map, there is our waste-lines sections nine through 13 up above, we have our.

170 00:30:31.950 --> 00:30:42.840 Scott Christian:  json, and so the json if we look at the first one says  DOT hazardous true if you look down at the image there's an x and showing that it is true.

171 00:30:44.520 --> 00:30:46.440 Scott Christian: Then we go to printed DOT information.

172 00:30:47.940 --> 00:30:55.020 Scott Christian: And we see the same thing that's printed in section nine is also what was on the previous slide to for consistency sake.

173 00:30:55.500 --> 00:31:09.450 Scott Christian: And then, if we go through the rest of the waste line will see the container number the container type on the manifest it says DM there's also an optional field for description that shows, those are metal drums give a little more.

174 00:31:10.650 --> 00:31:28.440 Scott Christian: info for the site was to gather that information same thing with quantity and unit of measurement and, finally, that has just placed us in this example, there are no State waste codes or Texas Waste codes so they don't show up that's an empty array and optional right.

175 00:31:30.480 --> 00:31:37.980 Scott Christian: So that's in there for you all, and when you download, the slides let's go to the next slide so.

176 00:31:39.630 --> 00:31:53.340 Scott Christian: To bring us all back why use our API and David kind of summed it up great on and through the slide is this idea of the same reason you just nail gun instead of a hammer.

177 00:31:55.710 --> 00:32:05.220 Scott Christian: A hammer and nail into boards and it will take you a long time to do it and you might bust your thumb or you might bend a nail.  A nail gun is going to do it.

178 00:32:07.980 --> 00:32:09.870 Scott Christian: get it done in a.

179 00:32:11.970 --> 00:32:19.020 Scott Christian: repetitive repeatable motion with the same quality of every nail going in with less chance you're gonna bust your thumb.

180 00:32:20.190 --> 00:32:24.030 Scott Christian: um and think about that, with an API.

181 00:32:25.050 --> 00:32:30.750 Scott Christian: Well repeatable you're going to improve your compliance by having your system.

182 00:32:33.600 --> 00:32:36.240 Scott Christian: submit the repeatable parts of those manifests off.

183 00:32:37.620 --> 00:32:41.250 Scott Christian: Reduced  user error, reduced data entry to problems.

184 00:32:42.540 --> 00:32:53.790 Scott Christian: it's reliable, you know you can build the build the API in the json offline and then upload it later on when you're back online.

185 00:32:54.810 --> 00:32:58.020 Scott Christian: So, these provide flexibility, just like that.

186 00:33:00.630 --> 00:33:12.480 Scott Christian: So why do we use json for the same exact reason we use rest widely adopted standards means more people can use it are implemented service, a lot of tools available to support developers.

187 00:33:13.740 --> 00:33:23.100 Scott Christian: So, and nearly every tool set available can interact with our rest API so Jason so when we get to the DEMO William Nicholas wrote.

188 00:33:26.700 --> 00:33:28.980 Scott Christian: His code in Python.

189 00:33:30.150 --> 00:33:36.660 Scott Christian: We developed the e-Manifest in Java, David Graham use JavaScript for something he was testing with.

190 00:33:37.950 --> 00:33:38.970 Scott Christian: visual basic

191 00:33:40.320 --> 00:33:49.800 Scott Christian:  and there's many commercial off the shelf products they use API, and a lot of those commercial offices chip sell products currently integrate into e-Manifest.

192 00:33:50.850 --> 00:33:55.080 Scott Christian: So, there's a lot of support for this out there.

193 00:33:57.150 --> 00:33:58.710 Scott Christian: let's go to the over that excellent.

194 00:34:00.450 --> 00:34:07.320 Scott Christian: Well, I've gotten through the first section of our agenda we're on to the second section, which is the current manifest workflows.

195 00:34:09.570 --> 00:34:14.820 Scott Christian: And I'm going to go through the fully electronic and then I'm going to go through the hybrid.

196 00:34:16.560 --> 00:34:17.220 Scott Christian: workflows.

197 00:34:19.830 --> 00:34:20.280 Scott Christian: So.

198 00:34:21.660 --> 00:34:22.020 Scott Christian: Thank you.

199 00:34:23.280 --> 00:34:35.880 Scott Christian: So, the background of this scenario is a fully electronic shipment where the TSDF company is arranging shipment for a generator that can use fully electronic manifest this this generator has at least to prepare.

200 00:34:37.860 --> 00:34:53.700 Scott Christian: The generator recently submitted notifications for their quadrennial sqg renotification and the TSDF needs to update their systems information regarding customer a lot of generators, if you have not updated your internal databases, this is also a public service announcement.

201 00:34:54.750 --> 00:35:05.730 Scott Christian: But a lot of generators going through this this year and then in this section I exercise, we will update a waste line and take the manifest to receipt so we're trying to create a.

202 00:35:07.620 --> 00:35:09.480 Scott Christian: Strict straightforward but typical workflow.

203 00:35:11.010 --> 00:35:12.210 Scott Christian: And if you could please.

204 00:35:14.190 --> 00:35:25.020 Scott Christian: Go to the next slide perfect So the first thing you need to do, and this has been remembered back several slides and several slides before that authentication.

205 00:35:25.890 --> 00:35:35.400 Scott Christian: So, the API key and key is sent and the token an expiration is sent back so that the in this case the tsp of customer service representative.

206 00:35:36.300 --> 00:35:50.850 Scott Christian: is using their in-house corporate system and either knowingly or unbeknownst to them, they will communicate to record info and the system will send the API key.

207 00:35:51.330 --> 00:35:57.960 Scott Christian: To progress info and then broke rental sent back to the system, the token so they can do their work in the expiration of that token.

208 00:36:00.330 --> 00:36:02.070 Scott Christian: Which is about 20 minutes.

209 00:36:03.570 --> 00:36:08.850 Scott Christian: The authentication the system's going to set this and that information.

210 00:36:12.600 --> 00:36:26.190 Scott Christian: Here are the examples, so the top example is a client URL example you can use the command line you'll see it's a request you get you're sending your request to.

211 00:36:27.420 --> 00:36:38.580 Scott Christian: record info and you're going to send in your API key and key of course API key are fake API keys never share your API keys are like your username password you know, keep those protected.

212 00:36:40.740 --> 00:36:57.900 Scott Christian: And then below that we have the Python code that William wrote so you can go look at his code, this is on our github site there's a link to it in the presentation, so please go check that out and we'll go right to the function that you need to learn about authentication.

213 00:37:00.690 --> 00:37:09.660 Scott Christian: Next, we have to find the generator so like I said they had recently updated their notification and the.

214 00:37:10.800 --> 00:37:12.960 Scott Christian:  TSDF customer service representative.

215 00:37:13.980 --> 00:37:26.580 Scott Christian:  needs to update  their system, so they send the request there's they've already been authenticated they send that request with such search criteria and refer info sends back the site or sites.

216 00:37:27.480 --> 00:37:35.970 Scott Christian: That was that match that search criteria and then using their interface, they can see what they need to update.

217 00:37:36.960 --> 00:37:54.810 Scott Christian: what's different about this slide is going to be on most of the subsequent slides is we've provided you with the with the json for each request and each response remember back several slides when I was talking about an API it sends a request and the other systems event back response.

218 00:37:55.830 --> 00:38:01.170 Scott Christian: You can use this to match so you're you know that your code is working and, of course.

219 00:38:02.280 --> 00:38:05.040 Scott Christian: Provided Williams function for the site search.

220 00:38:08.970 --> 00:38:28.380 Stephen Donnelly: And  quick note all the others sample json's they will be uploaded to the docket they're going to be  text files, but you will have all that sample json that you'll see in the presentation those will be available on the docket for you to download and use yes.

221 00:38:28.440 --> 00:38:30.810 Scott Christian: Thank you very much and they're also on github as well.

222 00:38:32.220 --> 00:38:34.590 Scott Christian: So is William's code.

223 00:38:36.390 --> 00:38:46.710 Scott Christian: So, creating a fully electronic manifest again same as before there's an example of a fully electronic manifest that your system can send.

224 00:38:47.730 --> 00:38:50.550 Scott Christian: And then you'll get a response back with.

225 00:38:52.080 --> 00:38:53.550 Scott Christian: The manifest tracking number.

226 00:38:54.600 --> 00:38:57.300 Scott Christian: Again, the Python code, does the same thing.

227 00:38:59.850 --> 00:39:05.400 Scott Christian: Now we're into the transaction, so the transporters phone has authenticated.

228 00:39:06.630 --> 00:39:08.610 Scott Christian: They are at the generator site.

229 00:39:09.930 --> 00:39:14.850 Scott Christian: They get there and they realize a couple of the drums aren't ready for.

230 00:39:17.430 --> 00:39:25.800 Scott Christian: for transport, they need to stay behind, for whatever reason, so the transporter using your phone APP or.

231 00:39:27.210 --> 00:39:41.040 Scott Christian: Third party service providers that they update manifest and either knowingly or unknowingly them they send the request the system's response sends a confirmation back the manifest has been updated.

232 00:39:42.270 --> 00:39:51.720 Scott Christian: With those new terms, so this will be able to see that see the difference and send the update you could also send that update as the as the as the format of.

233 00:39:52.650 --> 00:40:02.580 Scott Christian: How we built these very flexibly, but so now that that has happened, the transporter is now getting the manifest ready to sign.

234 00:40:03.210 --> 00:40:17.430 Scott Christian: And they send we have this service, called the UI links over some user interface service so from their application they send a service request and response with a universal resource locator basically a.

235 00:40:18.570 --> 00:40:19.290 Scott Christian: A link.

236 00:40:22.170 --> 00:40:28.830 Scott Christian: to sign that manifest and then that link can be sent from the transporters phone directly to the.

237 00:40:30.090 --> 00:40:36.060 Scott Christian: generator if they're using the same system, the same system email text.

238 00:40:37.290 --> 00:40:49.320 Scott Christian: However, it's wants to be developed and that generator click on that link go in be taken directly to the sign page review the manifest click quick sign and then.

239 00:40:50.520 --> 00:40:53.250 Scott Christian: The manifest is ready for the transporter do the same thing.

240 00:40:54.840 --> 00:40:55.710 Scott Christian: You go to the next slide.

241 00:40:58.560 --> 00:41:14.760 Scott Christian: And on this transport does the same thing they do not have to send it to anyone, because it's coming to them, they go into the system login  are taken to that review page click quick sign and now they're ready to start their engine and go on the road.

242 00:41:15.840 --> 00:41:18.510 Scott Christian: except for one thing, go the next slide.

243 00:41:19.890 --> 00:41:23.580 Scott Christian: printing out the D O T shipping paper, so the transporter.

244 00:41:24.660 --> 00:41:34.110 Scott Christian: After all, the signatures have can go request he manifest get her get the manifest attachments back, they have that.

245 00:41:34.770 --> 00:41:55.410 Scott Christian: PDF and, in this case, this manifest happens to be a one page manifest the prints off on an eight and a half inch by 11 pieces of paper, not the dot matrix printer not an impact printer not a printer that needs to be kept in certain degrees temperature just a.

246 00:41:56.550 --> 00:41:57.660 Scott Christian: portable printer.

247 00:41:59.850 --> 00:42:09.930 Scott Christian: or they could ask the generator to do it and print out that eight and a half 11 paper that he didn't have a printer with goes in the cab of the truck and the truck goes to the.

248 00:42:11.040 --> 00:42:12.870 Scott Christian: TSDF for signature.

249 00:42:15.630 --> 00:42:17.640 Scott Christian: And the TSDF user.

250 00:42:18.990 --> 00:42:26.760 Scott Christian: After the transporter has delivered the waste goes in sends the UI link service and indeed for these examples we're going to focus on quick sign.

251 00:42:28.230 --> 00:42:44.340 Scott Christian: There is another step under the Cross media electronic reporting rule Steve touched on that a little bit earlier and pretty much all know the finalization of manifest and signing, but this case we're going to just do a quick sign, because that can be done by.

252 00:42:45.480 --> 00:42:51.990 Scott Christian: The TSDFs and this TSDF user at the dock at the gate is quick signing the man.

253 00:42:55.470 --> 00:43:05.970 Scott Christian: So that was the fully electronic now it's hybrid and hybrid can be set up, from the beginning, but this time I wanted to throw a little bit extra.

254 00:43:07.170 --> 00:43:11.700 Scott Christian: curveball in the scenario so it's going to be the same exact scenario.

255 00:43:14.040 --> 00:43:15.210 Scott Christian: At least for the beginning part.

256 00:43:16.500 --> 00:43:31.710 Scott Christian: And, but then the generate when the  transporter shows up at the generator site, none of the registered signers are there and another public service announcement it's a reason to get people registered so if somebody.

257 00:43:33.090 --> 00:43:35.280 Scott Christian: The signers not there, then.

258 00:43:36.330 --> 00:43:41.070 Scott Christian: Somebody can register, but fortunately, the person there is.

259 00:43:42.450 --> 00:43:50.280 Scott Christian:  DOT trained, and they can sign the manifest, so they can do the hybrid portion of the manifest.

260 00:43:51.540 --> 00:43:58.560 Scott Christian: And finally, we're going to update the manifest type to hybrid and take the manifest through the final submission.

261 00:44:00.120 --> 00:44:14.190 Scott Christian: that's good so same exact scenario is before the tsp of customer service representative sends the manifest to manifest and RCRA info sends back a manifest tracking number.

262 00:44:15.600 --> 00:44:24.000 Scott Christian: same exact function that William wrote and used on the previous one, was being reused to that on this on this example.

263 00:44:25.440 --> 00:44:26.340 Scott Christian: right but.

264 00:44:27.450 --> 00:44:28.140 Scott Christian: Like I said.

265 00:44:29.280 --> 00:44:30.000 Scott Christian: The.

266 00:44:31.470 --> 00:44:39.270 Scott Christian: transporter gets there, and even though the generator confirmed with themselves, and they have already printed out their single piece of paper.

267 00:44:41.010 --> 00:44:44.190 Scott Christian: With everything they need to do they did their.

268 00:44:46.290 --> 00:44:51.960 Scott Christian:  shipment properly and the generator on site has signed on paper.

269 00:44:54.120 --> 00:45:02.430 Scott Christian: The transporter needs to make that adjustment, so now the transporter Luckily, the generator had planned ahead and add that piece of paper it printed.

270 00:45:03.480 --> 00:45:11.160 Scott Christian: takes that paper signature information and uploads it along with the change from fully electronic to hybrid.

271 00:45:12.330 --> 00:45:15.870 Scott Christian: And they send that up to up to recommend to a system.

272 00:45:17.640 --> 00:45:20.040 Scott Christian: And we now have a hybrid manifest.

273 00:45:21.330 --> 00:45:26.100 Scott Christian: So now, the transporter already has a generator information agent in there, though, the next likely.

274 00:45:27.930 --> 00:45:37.050 Scott Christian: chance, where he has a generator for information in there they're going to send you a link service, just like we saw in the previous example same example that nail gun example.

275 00:45:39.270 --> 00:45:51.390 Scott Christian: And they get back the URL to sign in their  application their tablet and they click sign and manifest is on its way so forget updates.

276 00:45:53.340 --> 00:46:02.310 Scott Christian: And this is the same exact processes before they get the updates they send it to a printer these a generator printer or another truck but it isn't an eight and a half by 11 piece of paper.

277 00:46:02.850 --> 00:46:16.500 Scott Christian: What we all use every day, not a 5-copy manifest.  So, it can go on the truck and, finally, just for, even though we are using quick sign for this.

278 00:46:17.310 --> 00:46:31.110 Scott Christian: These examples I sent it to the bulk sign page instead so you can send it to different pages, the link server so you can send to the dashboard in this case we're sending to the bulk sign also send it to an individual manifest without having to go on this.

279 00:46:32.130 --> 00:46:35.730 Scott Christian: there's a lot of flexibility there, please check out the github site.

280 00:46:36.810 --> 00:46:42.630 Scott Christian: Definitely check out Williams code and with that I'm going to hand this presentation over to him.

281 00:46:45.360 --> 00:46:56.010 William Nicholas: Thank you Scott Steve's gonna roll a DEMO for us here in a moment, and that will cover the transactions covered in the scenarios, we just saw but you know kind of live through the DEMO.

282 00:46:56.760 --> 00:47:04.710 William Nicholas: The DEMO the associated json and the PowerPoint as previously mentioned will be on the docket for this meeting.

283 00:47:05.460 --> 00:47:14.370 William Nicholas: runtime for this DEMO it's about 16 minutes, and you know, as I mentioned it'll cover what you've just seen it won't cover every possible scenario and.

284 00:47:14.730 --> 00:47:19.050 William Nicholas: I'll describe a bit more about some considerations for your review, on the other side of the DEMO.

285 00:47:19.740 --> 00:47:28.770 William Nicholas: I'll encourage you to turn up your volume the DEMO is a little bit quieter, and I want to make sure you all can hear it so take a moment to turn up your volume and Steve go ahead and roll the DEMO.

286 00:47:40.680 --> 00:47:45.960 Hello everyone, welcome to the you manifest Python services DEMO.

287 00:47:47.010 --> 00:47:56.670 you've just heard from us explaining the details of how to use our restful API services to.

288 00:47:58.050 --> 00:48:11.520 Set up sign and distribute links for generators transporters TSDFs to process a manifest foil electronically, and then additionally in a hybrid status.

289 00:48:12.780 --> 00:48:29.430 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.

290 00:48:29.970 --> 00:48:43.170 conduct this business and utilize services to take advantage of the benefits of fully electronic manifests on hybrid manifest and to make the process easier faster for you.

291 00:48:44.430 --> 00:49:02.070 So, just like the slides, we have the same objectives we're going to set things up authenticate and then generate sign and update a full electronic manifest However, unlike the slides we're going to start with the Python specific setup.

292 00:49:03.780 --> 00:49:18.750 To do that we're first going to bring in the record info teams, he manifests package This assumes that you've installed it ahead of time using you know for Python your pip install process or you can also do this via condo.

293 00:49:20.790 --> 00:49:35.250 Next, we're going to authenticate our account This assumes ahead of time that you have enabled API access in record info do you have questions about that feel free to consult the documentation or send us an email.

294 00:49:36.720 --> 00:49:52.380 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.

295 00:49:54.750 --> 00:50:09.930 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.

296 00:50:12.270 --> 00:50:20.970 That tells us with this authentication successful message that we are ready to go, and then we can access anything that our record info account has permissions for.

297 00:50:22.710 --> 00:50:32.670 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.

298 00:50:34.320 --> 00:50:36.300 here in our own tenant to.

299 00:50:38.190 --> 00:50:45.450 And that might take a second depending on how many parameters you put in and how much it has, to come back.

300 00:50:46.200 --> 00:51:01.290 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.

301 00:51:02.370 --> 00:51:08.790 So, we've got the one back that's you know, an EPA side ID our test generator right here and.

302 00:51:10.320 --> 00:51:23.070 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.

303 00:51:24.990 --> 00:51:29.700 And this includes information about say that generator right there.

304 00:51:31.140 --> 00:51:32.640 That we can pull from.

305 00:51:34.230 --> 00:51:35.250 This output here.

306 00:51:38.700 --> 00:51:42.750 And we save this file as a json object.

307 00:51:45.840 --> 00:52:03.660 Once we've saved that file here in our local folder we can use the SAVE command again and the manifest package to send that to record info and we get back confirmation that it's been saved and we get our manifest tracking number.

308 00:52:05.220 --> 00:52:25.440 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.

309 00:52:27.180 --> 00:52:30.720 and any other information that we would want to update.

310 00:52:33.540 --> 00:52:45.180 Once we've done that, we use the update command to send that out to record info and to make some changes we've gotten confirmation here that says that that has been successfully updated.

311 00:52:46.620 --> 00:52:52.860 Now, as the generator I can generate the I'm going to generate the link to sign that.

312 00:52:53.880 --> 00:53:03.600 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.

313 00:53:05.010 --> 00:53:10.620 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.

314 00:53:13.950 --> 00:53:19.170 And that's great so now returning here, I can generate a link.

315 00:53:20.370 --> 00:53:23.700 That I'll go ahead and send to the transporter.

316 00:53:39.360 --> 00:53:51.270 Now that I've gone ahead and done that, I'm going to pass things over to Scott serving as our transporter and will demonstrate how someone working through the transporter could sinus even from their phone.

317 00:53:52.800 --> 00:54:03.570 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.

318 00:54:04.590 --> 00:54:08.310 Where I click on scotty Christian rapper for.

319 00:54:09.360 --> 00:54:10.110 sign.

320 00:54:11.910 --> 00:54:25.530 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.

321 00:54:28.920 --> 00:54:31.200 right here, I can now click quick side.

322 00:54:32.820 --> 00:54:36.540 Last me some questions quick  sorry and.

323 00:54:37.830 --> 00:54:39.630 There we go I'm taking back to.

324 00:54:44.910 --> 00:54:47.670 The screen, where I can see a class that I had just signed.

325 00:54:49.650 --> 00:54:51.180 I will send it back to you.

326 00:54:54.540 --> 00:55:13.350 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.

327 00:55:14.580 --> 00:55:20.430 And you'll see here over in my folder structure as I refresh that.

328 00:55:21.600 --> 00:55:33.570 PDF and json come back with additional detail about that manifest and so, if I want to review that here in the process that's available to me.

329 00:55:34.590 --> 00:55:42.000 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.

330 00:55:42.870 --> 00:55:56.070 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.

331 00:55:58.830 --> 00:56:05.370 Thank you, William as the TSDF now I now have that URL link that.

332 00:56:06.510 --> 00:56:09.900 Williams application generated for me so I'm going to paste that here.

333 00:56:11.970 --> 00:56:14.160 Only again, you could just click it but.

334 00:56:16.050 --> 00:56:30.540 for purposes of this demonstration already have that URL copied to your clipboard so at this point, I can go through, I can specify the information generator information that generator ids correct transporting information all the stuff.

335 00:56:32.670 --> 00:56:38.190 Like down again, all the way down to the bottom, just like Scott, did I can click sound like such.

336 00:56:39.510 --> 00:56:42.090 confirm that all the information is again correct.

337 00:56:45.900 --> 00:56:52.260 Now that manifest has been signed by the generator transporter and it doesn't even receive facility, I'm going to hand it over to him.

338 00:56:55.410 --> 00:57:05.550 So, thanks to the work of David Scott and myself we've now set up the Python environment authenticated our account.

339 00:57:05.880 --> 00:57:26.580 found the generator created update and distributed for signature our electronic manifests and along the way we called out for updates and got those files back to us all with the simplicity of the restful API is and the repeatability of a Python process.

340 00:57:28.980 --> 00:57:35.520 Now we're going to take some time and show you how this might work with a hybrid manifest.

341 00:57:38.460 --> 00:57:49.440 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.

342 00:57:49.950 --> 00:58:02.100 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.

343 00:58:03.480 --> 00:58:12.480 Now that we've successfully done that, we will again pass a json object containing the information about our manifest to record info.

344 00:58:14.820 --> 00:58:22.740 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.

345 00:58:24.450 --> 00:58:33.360 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.

346 00:58:34.710 --> 00:58:48.990 And, like the full electronic process, we can accomplish a change, using the update command and, in this case, we're going to send the update Jason, but we've now changed the submission type to hybrid.

347 00:58:50.220 --> 00:58:51.870 So, when we send this out.

348 00:58:54.810 --> 00:59:01.590 we've updated the manifest and the status and record info will show as hybrid.

349 00:59:02.940 --> 00:59:12.090 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.

350 00:59:13.440 --> 00:59:26.250 Thank you get William so this new user is using a tablet they've already from there from their tablet and the APP that they're they built on their  company built on their tablet.

351 00:59:27.000 --> 00:59:34.050 The transporters taken directly to the link for the manifest that was just updated from electronic to hybrid.

352 00:59:37.080 --> 00:59:37.770 I log in.

353 00:59:39.270 --> 00:59:49.620 And I see of the test by and I see yes, it's now a hybrid manifest nice scroll down and there's a lot here, because the review is kind of big manifest.

354 00:59:51.840 --> 00:59:52.320 and

355 00:59:53.520 --> 01:00:05.460 generator and we see oh perfect so Jim tester, who is the generator and they  signed, and I can now quick sign this manifest so the information was uploaded.

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

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

358 01:00:24.240 --> 01:00:24.930 hand it back to away.

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

360 01:00:41.550 --> 01:01:03.420 I can go ahead and run that get attachments command and you'll see here and my file structure that I've gotten of information and this you manifest json object is going to include information about the manifest the status of it, and you know who has signed.

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

362 01:01:10.320 --> 01:01:26.220 So excellent now it's ready to be signed once it gets to the TSDF and so I'll generate a link specifically for our receiving facility and I'll send that over to David, who is serving as our receiving facility.

363 01:01:28.920 --> 01:01:37.470 All right, thank you, William again so for purposes of this demonstration I'm already logged in as our tsp.

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

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

366 01:01:50.160 --> 01:02:05.400 I can see, I have the option to compare sign or click sign these manifest that were just sent to me I'm going to go ahead and click science and that's all I needed the moment I click both ears like doll or.

367 01:02:06.510 --> 01:02:10.830 filter or just sign manifest that I want to sign.

368 01:02:12.330 --> 01:02:18.000 Also review if you'd like but for purposes of the day we're just going to go ahead and click sign both of these manifests.

369 01:02:19.050 --> 01:02:21.510 Again, confirm the information is correct.

370 01:02:24.090 --> 01:02:26.580 And our electronic manifest now complete.

371 01:02:29.070 --> 01:02:40.680 Thanks David so now we've managed to show you both fully electronic and hybrid options to complete the manifest process.

372 01:02:41.280 --> 01:02:54.060 all the way from the initial creation of the manifest through the signature at the receiving facility in this case, using Python and the restful APIs.

373 01:02:54.600 --> 01:03:10.020 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.

374 01:03:11.850 --> 01:03:26.070 we're going to come back to our presentation now, but if you have questions about this, we encourage you to reach out to us individually or to check out our github at github.com slash us EPA slash manifest.

375 01:03:27.090 --> 01:03:27.480 Thank you.

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

377 01:03:59.760 --> 01:04:09.030 William Nicholas: But the power of the APIs their flexibility, you can use Python you can use JavaScript you can use Java, you can use your own systems.

378 01:04:09.330 --> 01:04:21.600 William Nicholas: Your systems and your processes may be different, but your developers can adapt these API's to meet your current systems, your current processes using what you already have and what you already do.

379 01:04:22.920 --> 01:04:31.830 William Nicholas: A couple of regulatory points to note the receiving facility will need to finalize manifests and sign them as complete their to be compliant.

380 01:04:32.280 --> 01:04:46.350 William Nicholas: But the UI link service you saw is one touch API that can help you with that and another point, while the generator signs that hybrid manifest on paper it's the electronic representation of the signature, that is uploaded to the system via the API.

381 01:04:47.400 --> 01:04:56.310 William Nicholas: As I note in the DEMO if you have questions, we encourage you to reach out, we encourage you to make submission to the docket and also to check out our github.

382 01:04:57.120 --> 01:05:03.930 William Nicholas: If you have further questions, we can handle that later and for now I'm going to pass it over to test fields, who will open up our.

383 01:05:05.280 --> 01:05:06.750 William Nicholas: You know feedback and Q&A session.

384 01:05:09.090 --> 01:05:21.450 Tess Fields: Good afternoon, everyone, we have a good amount of time set aside in this next session to discuss some questions that we want to pose to you and answer questions that you all have put in the chat.

385 01:05:22.050 --> 01:05:27.690 Tess Fields: So, first, I will go through the questions that we would like to get your feedback on today.

386 01:05:28.560 --> 01:05:38.130 Tess Fields: So, I'll read through these questions first and we'll take comments on them or other related topics, so, if you would like to speak, please hit the raised hand button.

387 01:05:38.550 --> 01:05:47.640 Tess Fields: And I will go through in the order in which your hands are raised and unmute you and then after that we'll get to the Q&A session for questions in the chat.

388 01:05:48.330 --> 01:06:02.610 Tess Fields: So, our two questions for the section are do you think improved understanding of the existing electronic manifest workflow similar to today's presentation would encourage users to adopt electronic manifests.

389 01:06:03.150 --> 01:06:12.960 Tess Fields: And what types of assistance from EPA, for example, would be needed for users to adopt the existing electronic manifest process.

390 01:06:14.700 --> 01:06:26.760 Tess Fields: So, if you have thoughts on either of those questions or additional topics, please raise your hand I see, we have one hand raised by Teresa Colabella.

391 01:06:30.930 --> 01:06:32.010 Tess Fields: If you'd like to.

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

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

394 01:06:40.950 --> 01:06:41.610 Tess Fields: that's okay.

395 01:06:41.790 --> 01:06:42.360 Tess Fields: No worries.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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