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Document Record Detail



Full Document:
Title:REGULATORY STATUS OF SHIPMENT OF DENTAL X-RAY MATERIALS FROM MEXICO TO CANADA
RCRA Online Number:14841
Date:04/11/2014
To:Tuori
From:Devlin
Organization of Recipient:Harter Secrest & Emery LLP
Description: Federal RCRA hazardous waste regulations, per 40 CFR 261.2(c)(3) and Table 1 of 261.2, do not regulate the reclamation of off-spec commercial chemical products and characteristic byproducts provided these materials are reclaimed legitimately. Therefore, EPA’s hazardous waste import/export requirements would not apply to a shipment of intact unused off-spec dental x-ray packs and trimmings from unused dental x-ray packs generated in Mexico, with transit across the United States, destined for reclamation in Canada. A RCRA authorized state may regulate these materials more stringently than the federal program, although EPA believes the state’s requirements would not likely apply to transit only activities. However, should a transporter stop at a facility to consolidate a shipment in a state with more stringent requirements, the state may view such materials as a shipment of recyclable hazardous materials destined for precious metal recovery. In this case, the state may require that the consolidating facility comply with the state’s regulations equivalent to Part 266, Subpart F for precious metal recovery and Part 262, Subparts E and F for exports and imports of hazardous waste.
Regulatory Citation(s) : 261.2(c)(3), 262.50, 262.60, 266.70 EXIT disclaimer
Statutory Citation(s):NA Read US Code 42, Chapter 82 EXIT disclaimer
Topic(s):Exports; Hazardous Waste Recycling; Identification of Hazardous Waste; Imports; State Programs (RCRA)
Approximate Number of Hardcopy Pages:2
EPA Publication Number:NA
RPPC Number (if applicable): NA
Official OSW Policy:No

 

 
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