Waste Tire Manifest System Discussion of Proposed Revisions to the Waste Tire Manifest System Special Waste Committee November 4, 2004
WTMSIntroduction • Issues and Problems with Current WTMS • Board Direction • Background/History • Areas and Issues Considered in Analysis • Options for Board Discussion and Direction • Comparison of Options in Key Areas
Issues and Problems • 10-12,000 generators now required to submit forms • High volume of reporting forms submitted • Unreadable, incorrect or incomplete forms • Inconsistent adherence to reporting • Lack of adequate staffing for implementation of current system requirements • Lack of full participation in EDT.
Board Direction • Staff directed to develop options for the Board to simplify the tracking and reporting process • Improve efficiency and effectiveness • Reduce volume of paperwork
BackgroundHistory of WTMS • SB 744 (1993) – Established Hauler Registration Program and original manifest system • AB 117 (1998) – Req’d legislative report on Tire Program • Board recommended basis of current manifest system • SB 876 (2000) – Current system
History of WTMS • Public workshops • Testing phase • Regulatory package and comment periods • Implementation July 1, 2003 • Additional workshops in 2004 on ways to simplify and improve WTMS
Areas and Issues Considered • Goals and Objectives of the Tire Program and Manifest System • Enforcement Needs • Market Development Needs • Data Submittal • Stakeholder impacts • Impact on Board staffing resources • Legal impacts • Fiscal impacts
Goals and Objectives of the Tire Program • To reduce illegal storage and disposal of tires to minimize the effect on public health and the environment • To foster alternative uses or reuse of waste tires
Enforcement Regulatory Stakeholders • Generators • Tire Dealers, Auto Dismantlers, • Anyone generating 10 or more tires • Haulers • Anyone hauling 10 or more tires • End Users • Landfills, Transfer Stations, Recyclers
Tools in Enforcement • Inspections • Investigating Complaints • Surveillance • Permitting of Tire Facility • Hauler Registration • Manifest System • WTMS database
Manifest Information as an Enforcement Tool • During inspections • To target businesses operating illegally • As evidence in enforcement cases
Manifest Information as an Enforcement Tool - Inspections • Generators • Helps determine if using Registered Haulers • Haulers • Number of tires picked up and dropped off • Are tires going to authorized facility • End User • Reports unregistered Haulers • Verify that Hauler is using authorized facility
Manifest Information as an Enforcement Tool • Reports on potentially illegal activities • Generators not submitting manifests • Haulers with expired registrations • Account for tires picked up and delivered by Hauler
Manifest Information as Evidence in Enforcement Cases • Manifests can show that: • A Generator has used an unregistered hauler • Unregistered haulers hauled illegally to an authorized facilities • Lack of manifests at a Generator can be evidence that they are not using Registered Haulers • Multiple manifests can show • Hauler potentially illegally dumped tires
Manifest Information as Evidence in Enforcement Cases • WHAT • Violations • WHERE • Address of generator (pickup) • Address of end user (delivery) • WHO • TPID #, Business name • Role & Relationship: Generator, Hauler, End use • WHEN • Date of violation
Waste Tire Manifest System A Discussion of Options
Objectives of the Waste Tire Manifest System Specific to the Manifest System, SB 876, sought to: • Provide an accurate accounting that track tires from point of generation to disposal • Close the loop on accountability by including each party in the system (generator, hauler and end user).
Discussion of Options Option 1 -- Current Waste Tire Manifest System Option 2 -- Proposed Comprehensive Trip Log Option 3 -- Monthly Summary Report
Option 1 Current Waste Tire Manifest System • “Closes the Loop on Accountability” by requiring each party to a tire transaction – Generator, Hauler and End Use Facility to report on specific tire transactions. • Ability to cross check load and tire amount data between Hauler and Generator and End User at the trip level. • Provides detailed transaction data on tire pick up/delivery and hauler activity.
Option 2 -- Comprehensive Trip Log • Places responsibility on the Hauler to report for Generator and End Use Facility. • Generator, End Use Facility sign off and are provided “receipt” for tires picked up and delivered. • Provides detailed tire transaction data at the “load” level; date, tire, tire amt, etc. for enforcement. • Reduces reporting entities from 11,000 to 800+ and significantly reduces paper form submittal.
Comprehensive Trip LogCommon Pick up and Delivery CIWMB Only Hauler Reports - Hauler reports for both Generator and End Use Facility clients. There is only one form. Each client receives a Receipt for their records Hauler sends copy of CTL form to CIWMB for processing. Receipt A Generator 1 Receipt B Receipt C Generator 2 End Use Site
Option 3 --Monthly Summary Report • Requires Generator, Hauler and End Use Facility to report Monthly. • Provide summary information and totals on tires exchange activity. • Reduction in paper forms submitted.
Monthly Summary Report Monthly Summary Report Monthly Summary Report Generator Hauler End Use Facility Monthly Summary Reporting CIWMB Each stakeholder business must report monthly * Important* If the business plays more than one role, i.e. Generator as Hauler, they must complete a form for that role. In other words, a Generator who is also a Hauler must submit a form listing all Generator activity and submit a form for all Hauling activity.
CIWMB Internet Site End Use Site Generator 1 Electronic Data Transfer (EDT) Common Pick up and Delivery EDT Approved Hauler: - Generates WTMS information as part of their internal automated invoice and accounting systems. -- Uses their own Invoice as approved by CIWMB. -- Reports on behalf of their clients – Generators and End Users. -- Submits information monthly in a “batch” mode via Internet to CIWMB for processing. EDT Hauler Invoice Generator 2
End Use Site Generator 1 Web Based Electronic Data Transfer Common Pick up and Delivery CIWMB Internet Tires Web Site Web Based EDT Approved Hauler: -- Generates WTMS information on a transaction basis using their computer and accessing the Web based EDT data entry screen within the Board’s Tires Website. -- Reports on behalf of their clients – Generators and End Users. -- Uses their own Invoice as approved by CIWMB. -- Data entered daily, weekly. Web Based EDT Hauler Invoice Generator 2
Paper All parties report (except CTL) Must use CIWMB approved forms Must send in paper forms for processing within 14 days or monthly if Summary Report. EDT Hauler reports on behalf of Generator and End User Can use their own invoice, as approved by CIWMB Can send WTMS data either in “batch” mode or through daily data entry into Web based EDT portal. Distinctions between Paper and EDT Reporting
Conclusion of Presentation • Questions • Concerns
End of Presentation Slides
Comparison of Options • Attachment 4 • Information captured • Scannable • Load Tracking • Trip Reconciliation • Data for Enforcement • Market Development
Comparison of Options • Forms submitted annually • Reporting Frequency • Who Reports • Options for reporting • Automated system in place
Summary • Option 1 • Electronic data submittal – hauler reports • Paper based forms – all report • Tracks at load and trip level • Costs for development already incurred • Current 300,000 forms plus 132,000 EDT records
Summary • Option 2 • Electronic data submittal – hauler reports • Paper based form – hauler reports • Tracks at load level • Can be built on existing system, major costs for development already incurred • Estimate 75,000 forms (without electronic data submittal)
Summary • Option 3 • Electronic data submittal – all report • Paper based form – all report • Tracks at monthly activity level per hauler, generator and end user • Cannot be built on existing system, major costs for development • Estimate 132,000 forms (without electronic data submittal)
Comprehensive Trip LogMultiple Pick up and Delivery Hauler Sends 2nd Copy to CIWMB, retains 3rd Copy Hauler completes Part I New Trip Log, No Master Log Number Receipts Receipts C A A C B B Gen 1 End Use 1 Gen 2 Gen 3 Gen 4 End Use 2