Manufacturing Today - January/February 2017 - 10

10

SPACE TECH EXPO

SERVICE

F ABTECH

M A N U FA C T U R I N G

C ANADA MANUFACTURING

AH
S R EXPO 2017

duce such documents for inspection if
the inability to produce the document
is due exclusively to technical difficulty with EPA's WIETS, or its successor
system, for which the submitter bears
no responsibility.
Largely as proposed, EPA is requiring
electronic filing in AES for each export
shipment. The future AES filing compliance date, however, will be announced
separately to give exporters and their
authorized agents more time to revise
their filing software and fully test the
procedures, to be consistent with the
approach being used by the U.S. Customs and Border Protection (CBP) with
other government agencies.
Because the AES filing procedures
related to validating consent to export a shipment are a new requirement, only a limited number of the
exporters and authorized agents were
able to test file in a pilot the additional
information and validate their consents for individual hazardous waste
export shipments as part of their current AES filing procedures prior to the
effective date of the final rule.

L E A N

A ERODEF MANUFACTURING 2017

COLUMN BY | LYNN L. BERGESON

manufacturing-today.com JANUARY/FEBRUARY 2017

EPA is thus establishing a transition
period during which exporters may
choose to comply with either the electronic AES filing procedures or the
paper-based procedures established
at the port. EPA will coordinate with
CBP on the selection of the AES filing
compliance date.
The revisions to RCRA hazardous
waste manifest-related requirements
for hazardous waste export and import shipments are also being issued
in final largely as proposed, with few
changes. Exporters and receiving facilities are required under the rule
to list the consent number for each
waste listed in the manifest from the
effective date of rule, but the regulatory text no longer specifies exactly
where on the manifest the consent
numbers must be added.
Also in contrast with the proposed
rule, the final rule has removed the
inadvertently proposed duplicate
submittal of paper import manifests
to both the e-Manifest system and
EPA's International Compliance Assurance Division so that submittal

of paper import manifests to EPA's
International Compliance Assurance
Division is required only until the receiving facility can mail the manifest
to the e-Manifest system.
The proposed deletion of the requirement for transporters to give a
copy of the signed and dated manifest
to the U.S. customs official at the point
of departure from the United States
has been amended to reflect the transition period prior to the AES filing compliance date, during which the exporter may choose to either electronically
file EPA information in AES or follow
the existing paper-based process in
place at the port.
During the transition period, exporters will be required to inform
the transporter whether they have
chosen to follow the paper-based
process so that the transporter will
know whether he or she is required to
give a copy of the paper manifest to
the U.S. customs official. On or after
the electronic AES filing compliance
date, no transporter will be required
to give a copy of a paper manifest to
the U.S. customs official.
Finally, EPA elected not to issue in
final any limits to the number of hazardous waste codes that can be listed
to characterize a hazardous waste in
export notices, import notices, or export annual reports due to concerns
raised by commenters.
	 This is an important new rule.
Readers are urged to read it and understand its implications. mt
Lynn L. Bergeson is Managing Partner of Bergeson
& Campbell, P.C. (B&C®), a Washington, D.C. law firm
focusing on conventional, nanoscale and biobased
industrial, agricultural, and specialty chemical product regulation and approval matters, environmental
health and safety law, chemical product litigation, and
associated business counseling and litigation issues.
She is President of The Acta Group, with offices in
Washington, D.C., Manchester, UK, and Beijing, China,
and President of B&C® Consortia Management, L.L.C.
(BCCM), with offices in Washington, D.C.


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Table of Contents for the Digital Edition of Manufacturing Today - January/February 2017

Table Of Contents
Manufacturing Today - January/February 2017 - Cover1
Manufacturing Today - January/February 2017 - Cover2
Manufacturing Today - January/February 2017 - 1
Manufacturing Today - January/February 2017 - Table Of Contents
Manufacturing Today - January/February 2017 - 3
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Manufacturing Today - January/February 2017 - Cover3
Manufacturing Today - January/February 2017 - Cover4
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