EPA Proposes New Hazardous Waste Export/Import Rule

Update (10/19/15): EPA's Hazardous Waste Export-Import Revisions proposed Rule appeared in the Federal Register on October 19, 2015. 

On September 24, US EPA signed a proposed rule to update the requirements for import and export shipments of hazardous waste. A pre-publication version of the proposed hazardous waste rulemaking can be found here. According to the pre-publication version of the rule, the new standards aim to:

• Harmonize hazardous waste import-export requirements with rules for shipping between OECD nations;
• Enable electronic submittal of export- and import-related documents; and
• Enable electronic validation of consent in the Automated Export System (AES) for RCRA consent requirements.

EPA says the proposed RCRA revisions will consolidate and streamline the requirements and enhance documentation of the movement and disposition of hazardous wastes. In effect, the new rule seeks to create a single form that US hazardous waste exporters and importers can use to track shipments, as opposed to the many different forms for different situations currently in use.

The rule will affect businesses that ship RCRA-regulated hazardous wastes, universal wastes, and special wastes such as batteries to a different country for recycling, reclamation, or disposal.

Current RCRA Export Rules

To export hazardous waste under the current requirements, the exporter must:

• Submit an export notice to EPA;
• Receive EPA’s Acknowledgement of Consent (AOC) letter documenting consent by the country of import and any countries of transit;
• Meet RCRA manifest-related requirements for export shipments; and 
• Meet unique reporting and recordkeeping requirements.

The OECD, for its part, has revised its hazardous waste trans-boundary shipping standards many times since 1992. Some of these revisions have been adopted by US EPA into the RCRA hazardous waste requirements in the past.

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Tags: EPA, hazardous waste, new rules, RCRA