Manufacturing Today - January/February 2016 - 11

LYNN L. BERGESON | COLUMN BY

the cec report found
u.s. exports of spent
lead acid batteries to
mexico for recycling had
increased by 525 percent.
agencies.	 EPA	 proposes	 to	 incorporate	most	of	these	recommendations	
into	the	revised	regulations.

Discussion

P R O F I TA B I L I T Y

AH
S R EXPO 2016

C ANADA MANUFACTURING

B UY AMERICAN

S U S TA I N A B I L I T Y

The	changes	contemplated	under	the	
proposal	are	important.	In	effect,	the	
requirements	 under	 Subparts	 E	 and	
F	would	be	swept	into	Subpart	H,	and	
shipments	 subject	 to	 Subparts	 E	 and	
F	 would	 be	 regulated	 under	 Subpart	
H,	including	the	proposed	regulations	
in	 the	 proposal	 and	 existing	 Subpart	
H	regulations	not	subject	to	any	proposed	 change.	 Perhaps	 the	 most	 significant	 proposal	 relates	 to	 SLABs	
destined	for	offshore	recovery.	If	implemented,	 the	 proposed	 SLAB	 notification	 requirements	 would	 address	
the	concerns	noted	in	the	CEC	report	
referenced	 above	 and	 provide	 for	
more	 robust	 tracking	 of	 SLAB	 reclamation	operations,	particularly	those	
in	Mexico.
	 On	the	whole,	the	proposal	is	significant	and	likely	to	be	implemented	and	
thus	 worthy	 of	 careful	 consideration	
by	Manufacturing Today	readers.	While	
a	 final	 rule	 is	 not	 expected	 for	 some	
time,	understanding	the	changes	now	
will	 better	 prepare	 regulated	 entities	
for	the	changes	in	store.	mt

SERVICE

	 One	of	the	more	significant	changes	 is	 EPA's	 proposal	 that	 shipments	
of	SLAB	exported	for	reclamation	be	
accompanied	 by	 international	 shipping	 documents,	 akin	 to	 hazardous	
wastes	 manifests.	 Currently	 there	 is	
no	 requirement	 that	 SLAB	 exports	
be	covered	by	such	documents.	EPA's	
determination	that	some	revisions	to	
the	 SLAB	 import/export	 regulations	
are	 needed	 is	 featured	 in	 the	 2013	
CEC	 report	 and	 its	 recommendations.	Based	on	its	findings,	the	CEC	
report	 recommended	 that	 the	 U.S.	
require	the	use	of	manifests	for	each	
international	shipment	of	SLABs,	require	exporters	to	obtain	a	certificate	
of	 recovery	 from	 foreign	 recycling	
facilities,	 explore	 establishing	 an	
electronic	 export	 annual	 report	 and	
better	 share	 import	 and	 export	 data	
between	 environmental	 and	 border	

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. Lynn is President of The
Acta Group, with offices in Washington, D.C., Manchester, UK, and
Beijing, China, and President of B&C® Consortia Management LLC
(BCCM) with offices in Washington, D.C.

JANUARY/FEBRUARY 2016		 manufacturing-today.com			11


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Table of Contents for the Digital Edition of Manufacturing Today - January/February 2016

Contents
Manufacturing Today - January/February 2016 - Cover1
Manufacturing Today - January/February 2016 - Cover2
Manufacturing Today - January/February 2016 - 1
Manufacturing Today - January/February 2016 - Contents
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Manufacturing Today - January/February 2016 - Cover3
Manufacturing Today - January/February 2016 - Cover4
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