Are you using paper waste manifests to comply with Texas Railroad Commission's changes to 16 TAC, Chapter 4?

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What Our Clients Say

EnviroApps AER Manifesting surpasses competitors with its cost-effectiveness, user-friendly interface, comprehensive support, flexibility, and rapid implementation.

Kari B.
Environmental Advisor, Large Pipeline Company
The implementation was seamless, with reliable support from the EnviroApps team, resulting in an intuitive, adaptable system that we highly recommend for its ease of use and cost-effectiveness.

Fern M.
Senior Environmental Planner, Energy Producer
I will never go back to paper manifests again. I wish I had EnviroApps manifesting solution 20 years ago. We have so much visibility and the annual report will be a breeze.

Darcy W.
Environmental Lead, Large Refinery

EnviroApps RRC Changes

On December 17, 2024, the Railroad Commission of Texas (RRC) adopted significant revisions to 16 Texas Administrative Code (TAC), Chapter 4.
These changes took effect on July 1, 2025, and replace the long-standing Statewide Rule 8 (16 TAC §3.8).
The new rules aim to modernize waste tracking, improve environmental protection, and enhance accountability across the oil and gas industry.

Enhanced Documentation: Generators must use standardized Waste Profile Forms provided by the RRC or equivalent compliant documents.
Mandatory Waste Manifests: Every shipment must be accompanied by a manifest signed by all three parties—generator, transporter, and receiver.
Increased Accountability: All parties must retain records of manifests and waste profiles for a minimum of three years.
Electronic Reporting: Once the RRC's electronic filing system is operational, digital submissions will be mandatory within one year.
Interstate Waste Management: Waste originating outside Texas must include origin documentation and tracking identifiers from the respective state.

Waste Generators: Responsible for characterizing waste and initiating manifests. Must maintain detailed records and ensure audit readiness.
Waste Haulers: Must verify load details and sign manifests. Required to retain transport records and manifests.
Receiving Facilities: Must confirm receipt and report discrepancies. Transition to electronic reporting for compliance.

Do Nothing: Risky approach that may lead to non-compliance and penalties ($1,000 to $5,000).
Manual Adaptation: Involves updating paper forms and increasing storage. Prone to errors and inefficiencies.
Digital Transformation: Offers faster, more accurate, and scalable compliance. Requires selecting a system that fits organizational workflows.

Mandatory Multi-Party Signatures introduce delays and risks of incomplete documentation.
Three-Year Record Retention makes paper inefficient and costly.
Electronic Reporting Requirement makes digital readiness essential.
Audit and Inspection Readiness is hindered by paper-based systems.
Real-Time Coordination Challenges increase risk of discrepancies.
Scalability Issues make paper unsustainable for high-volume operations.
Cost Inefficiency from printing, storage, and error correction.
Digital Systems Solve These Problems: Instant access, automated validation, secure cloud storage, and seamless integration.