Navigating the RRC Changes to 16 TAC Chapter 4
A Guide to Simplifying Compliance for Oil & Gas Waste with Three Party E-Manifesting
Posted April 29th, 2025
What's going on?
On December 17th, 2024, the Railroad Commission of Texas (RRC) officially adopted revisions to 16 Texas Administrative Code (TAC), Chapter 4, which will take effect on July 1, 2025. These changes will supersede Statewide Rule 8 (16 TAC §3.8).
Why is this a big deal? It's the first time the RRC has overhauled waste management rules in 40 years.
These regulatory updates reshape the way oil and gas operators, waste transporters, and disposal companies in the state of Texas manage non-hazardous oil and gas waste, including produced water. You can review the adopted changes here.
Here's an overview of what's new, how it could impact your business, and clear steps on what you should do to ensure compliance.
Key changes
Generators must clearly characterize their waste using standardized Waste Profile Forms provided by the RRC or a similar compliant document.
ref. §4.190. Oil and Gas Waste Characterization and Documentation.
Each shipment must have a manifest (electronic or paper) signed by the generator, transporter, and receiver.
ref. §4.194 Recordkeeping.
All parties—generators, transporters, and receivers—are required to maintain records of manifests and waste profiles for at least three years.
ref. §4.194 Recordkeeping.
Once the Railroad Commission establishes an electronic filing system, electronic filing will becomes mandatory within one year, after which paper filings will no longer be accepted.
§4.130. Reporting.
Waste originating outside Texas must have clearly documented origins and tracking identifiers from respective state regulatory bodies.
ref. §4.195. Waste Originating Outside of Texas.
While there are some significant changes, for example to pit management and groundwater protection (which you can review here), this guide is focused on transportation and manifesting changes.
Impact by role
A compliant waste manifest involves three key roles: the generator, the transporter, and the receiver. While a single company may occasionally fulfill all three roles, they are typically handled by separate entities. As a result, effective coordination among the parties is essential to ensure the manifest is completed accurately and in compliance with regulatory requirements.
Waste generators
This is a broad category that includes oil and gas operators, E&P companies, or any other entity producing waste as part of oilfield activities.
Waste characterization
Responsibility for detailed waste characterization and initiating accurate manifests.
Recordkeeping
Enhanced recordkeeping obligations and audit readiness.
Waste haulers
Transports oil and gas wastes off-lease for a generator by any method other than pipeline. Typically, this is a trucking company or carrier.
Load verification
Obligation to verify and sign-off on waste load details accurately.
Recordkeeping
Mandated retention of manifests and relevant load records.
Receiving facilities
Stores, handles, treats, reclaims, or disposes of oil and gas wastes generated by a generator. A receiver of another person's oil and gas wastes may be a generator of their own oil and gas wastes. Typically, this is a midstream company operating SWDs, treatment, recycling, or other processing facility.
Receipt confirmation
Required to confirm waste receipt and immediately report discrepancies if the load is rejected.
Recordkeeping
Transition to electronic reporting to the RRC.
What are your options?
As with any change in business or life, you’re going to need to decide on a path forward. Here are the options many companies will face:
Do nothing.
Maybe you’ve got a great process going already, maybe you don’t. Either way you can always just choose to not react.
Adapt what you have.
Updating your manual processes by altering paper forms, increasing document storage, and managing more complicated recordkeeping is feasible but is often cumbersome, costly, and prone to error.
Go digital.
It’s no secret that when it comes to any type of data or document management, digital is the way to go. Digital processes are typically faster, easier, and less prone to error. With one big caveat…you need to choose the right system for your specific workflow, and for your organization.
Manual workflows won't cut it.
Although relatively straightforward, the new rules introduce more administrative complexity than ever before. Manual processes—paper manifests, spreadsheets, and texts, emails, and shared folders for communications—are not only inefficient, but they also put your compliance and environmental standing at risk.
It might be tempting to stay manual and not disrupt the status quo, but the short-term benefit of trying to minimize disruption are unlikely to outweigh the benefits of adopting a more efficient digital approach.
Here’s why:
One Document – Three Parties
All three parties (Generators, Haulers, and Receivers) need to produce, update, and verify a single shared manifest. Maybe that’s fine for a few dozen documents a month, but if you’re running hundreds of loads a week…that can get messy real fast.
Paper sucks.
If you’ve been in the industry for more than a day, you know that paper somehow ends up everywhere… while sometimes ending up no where. It’s easy to use (kind of), but not always easy to read, find, or report on. It’s not free, and it takes up space.
More Burden than Benefit
Manual processes don’t scale well. They need people to run them and time to administer. They put you at an increased risk of missing data, errors, or non-compliance. The “simplicity” of manual processes loses its legs pretty quickly whenever new requirements are introduced.
Why use an E-manifesting solution?
Using an E-Manifesting solution like IronSight for digital waste manifesting streamlines compliance processes, reducing the risk of errors and penalties. It also enhances visibility and coordination, ensuring that all stakeholders are informed and aligned throughout the workflow.
For E&Ps and Operators
Easily initiate, track, and document waste shipments from manned, and unmanned well sites, reducing compliance risks and enhancing operational efficiency.
For Transporters
Simplified manifest verification and automated record management reduce errors and administrative workload.
For Receivers
Real-time access to comprehensive waste shipment data streamlines receipt confirmation, reporting, and discrepancy management.
For Everyone
Going digital with a multi-party solution benefits everyone.
Fast & Accurate
Digital manifest creation is fast, accurate, and compliant with RRC requirements.
Real-time
Improve visibility and accountability across E&Ps, haulers, and receivers. If a change is made, it's immediately visible to everyone.
Automated
Eliminate manual tasks, ensure accurate records, and simplify audits.
Integrated
Provide secure data storage and integrate with existing systems, enabling seamless operations.
RRC Compliant waste manifesting with IronSight
We’ve designed a simple, easy to use workflow to support manifesting across all three parties. This page has a basic example outlined, but keep in mind that the workflow can be adapted to your specific requirements and situation.
If you have any questions, please reach out for a demo and we’ll walk you through what this looks like for your company and partners.
Creating and certifying a load
The IronSight “Job” is the how a Waste Generator (again, this is typically an E&P) indicates that they need waste to be transported. By creating a “Job” they are able to complete the Generator Information for a manifest, as well as a Field Ticket.
Waste characterization, pick-up and drop-off locations, cost centers, and more are all capture right at step one. At this point, the generator representative can certify the waste characterization, quantity, and other details.
-Generator name
-Physical and mailing address
-Telephone number
-RRC organization number
-Lease/facility/permit number (if applicable)
-Field name and county
-GPS coordinates of waste origin (if applicable)
-Description of waste (type, color, etc.)
-Estimated volume or weight (with units)
-Physical state (liquid, solid, sludge, etc.)
-RCRA classification (exempt or non-exempt)
-Waste characterization method (lab data or field knowledge)
-Generator signature and date
ref. §4.191
Scheduling and dispatching
After a job is created, it needs to be assigned to a service provider to execute. This can be done when creating the job, or if no transporter is assigned during creation, the job card can be dragged and dropped onto a company to assign it to them.
Once assigned to a service company, their dispatcher can drag and drop the job onto the optimal unit.
Pickup and delivery
When the driver picks up the load, they’ll be asked to verify that the load they are transporting matches what they were asked to transport.
The driver will verify the load at pick-up as well as at drop-off to provide an opportunity to ensure any changes made, like a different drop-off location, are captured.
Receiving
When the driver drops-off the load, delivery will be confirmed. The receiver, let’s say a salt-water disposal (SWD) operator, will then have the job displayed in IronSight as “Confirmed. No-signature.” A facility rep can review any loads pending a receipt signature and confirm or reject as needed.
After a facility rep completes their certification, a fully compliant e-manifest will be available for all three parties.
Reporting to the RRC
All completed and triple verified loads can be found in IronSight and bulk exported as a .csv to submit. PDF manifests can also be downloaded from IronSight to support each load.
Why use IronSight?
Other digital waste manifesting, or “e-manifesting” solutions exist, such as Galatea or Gemini. Here are a few reasons why IronSight could be the best option for your company.
Simple
Something we learned a long time ago is that field based software is only as good as it’s adoption. IronSight ensures that every user has a simple, easy experience.
Collaborative
When you have multiple parties involved in a manifest, it helps to have a system where multiple parties can be involved in a manifest. A simple concept, but one that can make all the difference.
Versatile
IronSight works best with all three parties involved, but if you're only able to pick a system for your own company only - IronSight can still work for you. Reach out to talk with us about how.
Connected
If you have a system you’d like connected with IronSight we can work together to make it happen.
SCADA
If you have meters at a pickup, or a drop-off location, actual volumes can be integrated into IronSight and onto a manifest. If you're a generator, jobs can be automatically created based on a tank reading.
Accounting systems
IronSight can pass manifest (and ticket) information through to a financial accounting system to simplify reporting.
More than a manifest
IronSight jobs can be fully functional digital tickets in addition to being a waste manifest. In fact, our e-manifesting workflow is built on our e-ticketing workflow. Combining the ticketing and the manifesting workflows helps further streamline your processes. Additionally, if there are any digital forms that need to be captured, like a JSA, IronSight can do that as well.
Interested in
learning more?
Schedule a call with our team where we can learn about your operations and provide a tailored demo.
Resources and FAQs
Find links to resources and answers to questions.
The Texas Administrative Code (TAC), Title 16, Part 1, Chapters 1 through 20, commonly referred to as 16 TAC, are where the official rules of the Railroad Commission of Texas are documented. Chapters 3 and 4 are the relevant chapters related to this guide. You can review 16 TAC here.
Statewide Rule 8, formerly codified as 16 TAC §3.8 was the previous regulation for pits, including saltwater disposal pits, oilfield waste recycling, and oil and gas waste disposal. The changes made to 16 TAC chapters 3 and 4 are still commonly referred to as the Rule 8 changes.
You can use IronSight for waste manifesting only, however most companies will find that because their team are already using IronSight for the manifest, adding in things like line items for a costed ticket, and required forms like JSAs, make things easier for everyone. Contact us to learn more
Yes, IronSight can be used to support any required manifesting or other fluid transfer documentation. If you'd like to explore IronSight for other manifesting requirements please contact us to discuss further.
Yes, IronSight can be used for other waste streams. However, we strongly recommend rolling out for non-hazardous waste first, and then bringing on hazardous later.