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California Integrated Waste Management BoardWaste Tire Manifest
System
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California Integrated Waste Management Board
Report on Waste Tire Manifest System
Electronic Data Transfer Pilot Project (EDT) expansion
Retreader Issue
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California Integrated Waste Management BoardWTMS Manifest
Background 1993 – SB 744 established the Hauler
Registration Program and initial manifesting requirements for haulers.
1998 - AB 117 required a report to the Legislature on the Used and Waste Tire Programs. The 1999 report recommended “closing the loop” and provided the basis for SB 876.
2000 - SB 876 established the “California Uniform Waste and Used Tire Manifest” system which requires each party to a waste tire transaction to submit a copy of the manifest form to CIWMB.
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California Integrated Waste Management Board
SB 876, PRC 42961.5, provides two means of collecting and submitting waste tire manifest information to the Board:
Paper based form submittal Electronic Data Transfer
Both methods are currently in effect.
EDT Pilot Project Expansion
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California Integrated Waste Management Board
PRC 42961.5, requires that
Waste / Used Tire Generator
Hauler End Use Facility
each complete a Manifest form and/or trip log.
“Closing the Loop” on accountability
EDT haulers are permitted to use their own CIWMB approved forms.
Report tire transaction data on behalf of their clients – pickup and deliveries
Paper EDT
EDT Pilot Project Expansion
Collection
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California Integrated Waste Management Board
PRC 42961.5, requires that
Waste / Used Tire Generator
Hauler End Use Facility
submit, via the mail, a copy of that form to CIWMB for processing.
EDT haulers submit WTMS data monthly on pick ups, hauls and deliveries.
Submittal is done electronically via the Board’s Website/Internet
Paper EDT
EDT Pilot Project ExpansionSubmittal
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California Integrated Waste Management Board
Paper Manifest Processing Steps:
1. Collect forms from the Post Office2. Open mailed forms and prepare for scanning3. Scan the form into the computer, verifying form
template4. Scan form for data accuracy using OCR5. Correct questionable handwritten entries6. Move corrected and completed form data into WTMS
data base for the reconciliation process.
EDT Pilot Project Expansion
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California Integrated Waste Management Board
Forms from each of the 3 participants come in at different times.
60,000 backlog of forms to be processed
Staff and time intensive.
EDT data is processed electronically in large volumes.
EDT data is submitted complete loads.
Much less staff time spent in processing EDT data.
No backlogs exist for EDT data.
Paper EDT
EDT Pilot Project ExpansionProcessing
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California Integrated Waste Management Board
WTMS paper forms have a lower data accuracy rate than EDT data.
Critical data is often missing; Pick up or delivery, decal no., etc.
Waste Tire Trips are more difficult to reconcile due to lower data quality and varying dates when the forms are received.
Staff follow up often required via telephone, “advisory letters” and field visits.
EDT data is electronically processed and verified to ensure data is complete.
If data is not complete, EDT participant must correct and resubmit.
EDT has a high trip reconciliation rate.
Paper EDT
EDT Pilot Project ExpansionData Quality
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California Integrated Waste Management Board
EDT Pilot Project ExpansionProfile of waste tire hauler community
850 (est.) registered waste tire haulers 50 large volume haulers 100 - 300 middle tier haulers 450 - 600 small business
haulers
Currently 2 large volume haulers are in EDT Pilot program.
EDT Pilot Project in production since July 1, 2003.
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California Integrated Waste Management Board
EDT Pilot Project ExpansionAnalysis of WTMS Paper Manifest Option and
EDT Large volume hauler submission rates:
25 haulers account for one-half all forms received to date
14 haulers account for over one-third of all forms received to date
While it would be desirable to have 25 haulers in the EDT Pilot program, a more realistic estimate is that 14 – 15 haulers could be brought into EDT program through a moderate expansion of the pilot project. Staff estimate that 14 – 15 haulers in the EDT Pilot Project would decrease current paper form processing volumes by one-third or more.
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California Integrated Waste Management Board
EDT Pilot Project Expansion EDT and Industry
Businesses say that they can see the potential for EDT in their business but lack technical resources to make it happen.
EDT Pilot Project Haulers find the WTMS easier to administer than the paper based forms.
Industry would welcome some sort of assistance to achieve more efficiency in the WTMS reporting requirements.
CIWMB has developed and provided an EDT User’s Guidance Manual to approximately 25 waste tire haulers.
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California Integrated Waste Management Board
EDT Pilot Project Expansion Benefits of expanded EDT Pilot Project
Leverages existing industry business practices.
Significant cost savings/avoidance for CIWMB in staff time and resources.
Faster data collection, submittal and processing times while ensuring higher data quality.
Proven record of CIWMB EDT Pilot Project success since July 1, 2003.
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California Integrated Waste Management Board
Proposed Approach for EDT Pilot Expansion
Phase I Assessment $ 25 KReadiness, software type and experience,level of automation, onsite staff support.
Phase II Focused technical assistance $ 125 KAs appropriate, based on above, assist with programming changes and/ or identify
specificbusiness processes to be modified to
participatein EDT. (20 – 25 haulers this FY with
additional haulers in future FYs.)
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California Integrated Waste Management Board
Proposed Approach for EDT Pilot Expansion
Phase III Development of a standaloneautomated system for use byHaulers $
100 K
To address small businesses, with minimal automated capabilities, staff would develop a a standalone system (MS Access), to provide basic customer account information and the ability to capture key-entered data for submission electronically and generate “EDT Manifest” data for submittal to CIWMB.
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California Integrated Waste Management Board
Retreader Issue
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California Integrated Waste Management Board
Retreader Issue
Under the previous manifest system, from 1995 to 2003, retreaders were allowed to prepare a single invoice for each pick up of tire casings and attach those invoices to a single manifest for the day’s route.
Retread tire casings fall within the definition of a “waste and used tire” as defined in Public Resources Code 42805.5 and 42807.
Retreaders maintain that because the retread tire casing is “owned” by their clients and not the property of the retreader, the likelihood of illegal disposal is nil. Once the casing is retreaded, it no longer falls under the definition of a waste or used tire.
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California Integrated Waste Management Board
Retreader Issue
Retreader position
Retreaders feel they are unduly burdened by the manifesting requirements.
Retreaders are asking the Board to modify current requirements but still allow for them to submit the needed tire documentation on quantities of casings being retreaded, recycled or disposed.
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California Integrated Waste Management Board
Retreader Issue
Objective:Ease the burden placed upon the Retread Industry without sacrificing the information needed to track the flow of casings and waste
tires.
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California Integrated Waste Management Board
Retreader Issue
Stakeholder Impacts If manifesting requirements are changed for
retread industry, other tire groups may seek special consideration.
Staff believe the retread situation is unique and that different manifesting requirements be developed for them. This could be done with emergency regulations.
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California Integrated Waste Management Board
Summary EDT Expansion
Staff to proceed with the expansion of the EDT Pilot Project within the framework of the existing program.
Retreader Issue Staff to work with stakeholders and
interested parties to draft emergency regulations.