Manufacturing Today - January/February 2017 - 9

LYNN L. BERGESON | COLUMN BY

A ERODEF MANUFACTURING 2017

AH
S R EXPO 2017

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

C ANADA MANUFACTURING

L E A N

The	rule	expands	the	applicability	of	a	
reorganized	and	clarified	40	C.F.R.	Part	
262,	Subpart	H	to	all	hazardous	waste	
transboundary	 shipments,	 including	
those	 import	 and	 export	 shipments	
of	 universal	 waste	 managed	 under	 40	
C.F.R.	Part	273	and	specific	hazardous	
wastes	 such	 as	 SLABs	 managed	 un-

F ABTECH

The New Rule

der	 40	 C.F.R.	 Part	 266.	 Exporters	 of	
hazardous	 waste	 shipments,	 and	 the	
transporters	carrying	such	shipments,	
to	Canada,	Chile,	Mexico,	and	any	nonOECD	 country	 are	 now	 required	 to	
comply	with	OECD	procedures	under	
new	or	renewed	consents	issued	after	
the	effective	date	of	the	rule.	
	 Importers	 and	 receiving	 facilities	
of	 hazardous	 waste	 shipments,	 and	
the	 transporters	 carrying	 such	 shipments,	 from	 Canada,	 Chile,	 Mexico,	
and	any	non-OECD	country	similarly	
are	 required	 to	 comply	 with	 OECD	
procedures	 under	 new	 or	 renewed	
consents	 issued	 to	 either	 the	 foreign	
exporter	or	the	U.S.	importer	after	the	
effective	date	of	this	action.
	 Key	aspects	of	the	final	rule	include	
the	 following	 provisions.	 Submittals	
are	 required	 for	 each	 of	 the	 following:	 	 export	 annual	 reports,	 export	
exception	 reports,	 import	 notices,	
and	 receiving	 facility	 notifications	 of	
the	need	to	arrange	alternate	management	or	return	of	an	individual	import	
shipment.	 No	 submittals	 to	 EPA	 will	
be	required	for	each	of	the	following,	
until	the	electronic	import-export	reporting	 compliance	 date	 (on	 or	 after	
which	 electronic	 submittal	 of	 these	
documents	to	EPA	using	EPA's	Waste	
Import	Export	Tracking	System	(WIETS),	or	its	successor	system,	will	be	
required):	export	confirmations	of	receipt,	export	confirmations	of	recovery	or	disposal,	import	confirmations	
of	 receipt,	 and	 import	 confirmations	
of	recovery	or	disposal.
	 	The	final	rule	clarifies	that	electronic	storage	in	EPA's	WIETS	of	electronically	submitted	documents	will	satisfy	
EPA's	 recordkeeping	 requirements	
provided	 copies	 are	 readily	 available	
for	viewing	and	production	if	requested	 by	 any	 EPA	 or	 authorized	 state	 inspector,	and	that	the	submitter	will	not	
be	 held	 liable	 for	 the	 inability	 to	 pro-

SERVICE

	 That	 revisions	 were	 needed,	 according	 to	 EPA,	 was	 a	 view	 reinforced	 by	 other	 sources.	 For	 example,	 the	 2013	 Commission	 for	
Environmental	 Cooperation	 (CEC)	
report	 noted	 that	 the	 export	 of	
SLABs	 could	 benefit	 from	 the	 use	
of	 international	 movement	 documents	 for	 each	 international	 shipment	of	SLABs.	
	 The	 2015	 EPA	 Office	 of	 Inspector	
General	 report	 concluded	 that	 electronic	 reporting	 was	 needed	 and	
would	 improve	 accountability	 and	
increase	 the	 tracking	 of	 individual	
import	shipments	of	hazardous	waste	
and	 requiring	 EPA	 consent	 to	 an	 import	 notice	 submitted	 by	 either	 the	
foreign	exporter	or	the	U.S.	importer.

SPACE TECH EXPO

	 In	 terms	 of	 application,	 the	 revisions	 to	 export	 and	 import	 requirements	in	the	final	rule	generally	affect	
four	 groups:	 all	 persons	 who	 export	
or	 import	 (or	 arrange	 for	 the	 export	
or	import)	hazardous	waste	for	recycling	or	disposal,	including	those	hazardous	wastes	subject	to	the	alternate	
management	 standards	 for	 (a)	 universal	waste	for	recycling	or	disposal,	
(b)	 spent	 lead-acid	 batteries	 (SLAB)	
being	shipped	for	reclamation,	(c)	industrial	 ethyl	 alcohol	 being	 shipped	
for	reclamation,	(d)	hazardous	waste	
samples	 of	 more	 than	 25	 kilograms	
being	 shipped	 for	 waste	 characterization	or	treatability	studies,	and	(e)	
hazardous	recyclable	materials	being	
shipped	 for	 precious	 metal	 recovery;	
all	 recycling	 and	 disposal	 facilities	
that	 receive	 imports	 of	 such	 hazardous	 wastes	 for	 recycling	 or	 disposal;	
all	persons	who	export	or	arrange	for	
the	 export	 of	 conditionally	 excluded	
cathode	 ray	 tubes	 being	 shipped	 for	
recycling;	 and	 all	 persons	 who	 transport	any	export	and	import	shipments	
described	above.	Many	other	industry	
sectors	are	potentially	affected.

JANUARY/FEBRUARY 2017		 manufacturing-today.com			9


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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
Manufacturing Today - January/February 2017 - 4
Manufacturing Today - January/February 2017 - 5
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Manufacturing Today - January/February 2017 - 101
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Manufacturing Today - January/February 2017 - 133
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Manufacturing Today - January/February 2017 - 135
Manufacturing Today - January/February 2017 - 136
Manufacturing Today - January/February 2017 - Cover3
Manufacturing Today - January/February 2017 - Cover4
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