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Show details for Air Emissions (RCRA)Air Emissions (RCRA)
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04/11/2014REGULATORY STATUS OF SHIPMENT OF DENTAL X-RAY MATERIALS FROM MEXICO TO CANADAMemo
 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.
 
09/29/2009IMPORT OF PCB WASTES FOR DISPOSALMemo
 Description: Movement of PCB waste from a USCG cleanup site on the Yap Islands to a TSCA-approved disposal facility in the United States does not constitute impermissible import of PCBs for purposes of TSCA. PCB cleanup activity by the USCG on the Yap Islands is subject to all rules and regulations that would apply if the USCG were performing a cleanup in the United States or territory thereof. EPA must therefore construe programs and services regarding the cleanup to be made available. If this cleanup were being conducted in the United States, movement of the resulting cleanup wastes to any EPA-approved disposal facility in the United States would be authorized, even if the waste would cross a United States boundary or the boundary of a US Customs Territory.
 
09/19/2008Draft Guidance on EPA Identification of U.S. Pre-Approved Facilities to Receive Hazardous Waste Imports from OECD Member CountriesPublication
 Description: This draft guidance document suggests an approach on how United States recovery facilities may request that EPA identify them as a ‘pre-approved’ facility for purposes of receiving RCRA hazardous wastes, originating in OECD Member countries, for recovery in the United States.
 
08/01/2008EPA’S RULE TO ALLOW IMPORTATION OF PCB-CONTAINING WASTE FROM MEXICO FOR INCINERATIONMemo
 Description: EPA is analyzing and considering all viewpoints expressed in making a final determination on whether to grant the request to import PCB-containing waste from Mexico for incineration.
 
05/03/2005IMPORT OF CATHODE RAY TUBE (CRT) CULLET FOR USE AS RAW MATERIALMemo
 Description: Shipment of CRT glass cullet is generally viewed as a commodity and not a waste.
 
04/15/2005USE OF THE HAZARDOUS WASTE MANIFEST FOR IMPORT SHIPMENTS OF MAQUILADORA HAZARDOUS WASTESMemo
 Description: Importers are allowed to physically consolidate hazardous waste shipments before they enter the US as long as the manifest accurately reflects the consolidated shipment. The manifest must identify the individual foreign sources (i.e., the generators) that contributed wastes to the consolidated shipment and the hazardous waste types and quantities that each source contributed to the consolidated load. Service companies or TSDFs importing maquiladora hazardous wastes are not themselves generators. Instead, it is the individual maquiladora plants that are generators and, therefore, must be shown on the manifest. Provides examples of adequate manifesting options.
 
07/22/2004NOTICE AND CONSENT OF TRANSBOUNDARY MOVEMENTS OF MUNICIPAL SOLID WASTEMemo
 Description: The Federal government lacks the statutory authority to regulate notice and consent for transboundary movements of municipal solid waste under the bilateral agreement between the United States and Canada. The process for exporting hazardous waste to the US includes a notice of intent to export and a process whereby the US may consent to the import.
 
07/22/2004NOTICE AND CONSENT OF TRANSBOUNDARY MOVEMENTS OF MUNICIPAL SOLID WASTEMemo
 Description: The Federal government lacks the statutory authority to regulate notice and consent for transboundary movements of municipal solid waste under the bilateral agreement between the United States and Canada. The process for exporting hazardous waste to the US includes a notice of intent to export and a process whereby the US may consent to the import.
 
06/14/2004MOVEMENT OF MUNICIPAL SOLID WASTE FROM CANADA INTO MICHIGANMemo
 Description: All municipal solid waste (MSW) must be disposed of in a MSW landfill that is licensed and regularly inspected. Landfills must comply with requirements including responsible siting, safe operation and design, regular ground water monitoring, corrective action, closure and post-closure care. U.S. Customs Service visually inspects trucks importing waste for suspicious leaks and uses x-ray and radiation monitoring equipment.
 
03/12/2004DISPOSAL OF CANADIAN MUNICIPAL SOLID WASTE IN MICHIGAN LANDFILLSMemo
 Description: Canada is permitted to send trash to the U.S. by international law. Imported waste is managed according to U.S. regulations. Landfills are licensed and inspected by the state. Federal RCRA requirements and state regulations have rules to make landfill owners prevent leaks into the soil and water, cover the waste every day, and operate the landfills under careful controls.
 
12/16/2003DISPOSAL OF CANADIAN MUNICIPAL SOLID WASTE IN NEW YORK LANDFILLSMemo
 Description: Shipments of municipal solid waste (MSW) between the U.S. and Canada occur routinely. The U.S. has a well-established regulatory system to determine what can be responsibly managed in landfills. Properly permitted and compliant MSW landfills enable solid waste disposal that appropriately minimizes the risk to public health and the environment.
 
08/26/2003TRANSBOUNDARY SHIPMENTS OF MUNICIPAL SOLID WASTE BETWEEN THE UNITED STATES AND CANADAMemo
 Description: EPA is committed to the safe international movement of municipal solid waste from Canada into the United States. Currently, there is no statutory authority under RCRA for providing notice and consent of municipal solid waste imports and exports. EPA is working on a legislative proposal to Congress regarding the transboundary movement of waste between the United States and Canada. EPA is also working with Customs through a Memorandum of Understanding to address security concerns regarding transboundary shipments and to strengthen the cooperation between agencies to improve border security. EPA additionally works with the Canadian government, U.S. state agencies, and the Department of Homeland Security on border security issues.
 
08/26/2003TRANSBOUNDARY SHIPMENTS OF MUNICIPAL SOLID WASTE BETWEEN THE UNITED STATES AND CANADAMemo
 Description: EPA is committed to the safe international movement of municipal solid waste from
Canada into the United States. Currently, there is no statutory authority under RCRA for providing notice and consent of municipal solid waste imports and exports. EPA is working on a legislative proposal to Congress regarding the transboundary movement of waste between the United States and Canada. EPA is also working with Customs through a Memorandum of Understanding to address security concerns regarding transboundary shipments and to strengthen the cooperation between agencies to improve border security. EPA additionally works with the Canadian government, U.S. state agencies, and the Department of Homeland Security on border security issues.
 
08/26/2003TRANSBOUNDARY SHIPMENTS OF MUNICIPAL SOLID WASTE BETWEEN THE UNITED STATES AND CANADAMemo
 Description: EPA is committed to the safe international movement of municipal solid waste from Canada into the United States. Currently, there is no statutory authority under RCRA for providing notice and consent of municipal solid waste imports and exports. EPA is working on a legislative proposal to Congress regarding the transboundary movement of waste between the United States and Canada. EPA is also working with Customs through a Memorandum of Understanding to address security concerns regarding transboundary shipments and to strengthen the cooperation between agencies to improve border security. EPA additionally works with the Canadian government, U.S. state agencies, and the Department of Homeland Security on border security issues.
 
04/17/2002APPLICABILITY OF TRANSPORTER REQUIREMENTS TO HAZARDOUS WASTE IMPORTS AND EXPORTS Memo
 Description: The Part 263 requirements apply to persons transporting manifested shipments of hazardous waste within the United States. An EPA ID number is not required if the transporter is not required to have a manifest. Transporters that export waste must give a copy of the manifest to the U.S. Customs Service official at the point of departure from the United States. The point of departure occurs at the port of exit. A hazardous waste shipment would not require a manifest once the ocean carrier leaves the port. Ocean carriers importing hazardous waste into the United States would not need a manifest or an EPA ID number before the shipment is off-loaded at a port (SEE ALSO: 66 FR 28240; 5/22/01). The ocean carrier remains subject to other applicable requirements (e.g., Department of Transportation (DOT) regulations). Each railroad firm and trucking company is responsible for obtaining an EPA ID number for intermodal service. If an ocean carrier is not arranging for the inland transport of waste, then the carrier is not directly responsible for ensuring that the inland transporters have EPA ID numbers, but should verify with the company arranging the inland transport.
 
09/01/2000LAND DISPOSAL RESTRICTIONS FOR IMPORTED HAZARDOUS WASTESQuestion & Answer
 Description: Characteristic waste decharacterized prior to entering the United States not subject to land disposal restrictions (LDR) treatment standards or paperwork requirements. U.S. importer is responsible for hazardous waste identification. Importer must comply with all applicable RCRA standards and special importer requirements for waste that is hazardous at point it enters the United States.
 
07/21/2000CONCERNS ABOUT IMPORTING OF TOXIC WASTEMemo
 Description: Imported hazardous wastes subject to RCRA cradle-to-grave management system. Most hazardous waste imports are for recycling. Imports are relatively small portion of hazardous waste managed domestically.
 
06/01/2000IMPORT REQUIREMENTS FOR RCRA EXEMPT WASTEQuestion & Answer
 Description: Treatability samples exclusion extends to waste that originates outside of United States. Laboratory importing treatability samples from foreign facility not subject to import requirements if samples are managed in accordance with 261.4(e) exclusion.
 
03/01/2000FREQUENTLY ASKED QUESTIONS ON IMPORTS AND EXPORTS OF HAZARDOUS WASTE BETWEEN THE MEMBERS OF THE ORGANIZATION FOR ECONOMIC COOPERATION AND DEVELOPMENT (OECD)Question & Answer
 Description: Organization for Economic Cooperation and Development (OECD) is an international organization designed to foster economic growth, employment, and rising standard of living between member countries. Green, amber, and red lists of wastes dictate level of control placed on importing and exporting particular wastes. Importers and exporters must meet Part 262, Subpart H requirements when hazardous waste is shipped between U.S. and OECD countries for recovery operations. U.S. importers and exporters should comply with Subparts E and F when dealing with Canada or Mexico due to separate bilateral agreements. Generator must comply with Subpart H if they act as notifier. Notifier is person who has possession or legal control of waste when transfrontier movement of waste occurs.
 
02/01/2000FREQUENTLY ASKED QUESTIONS ON THE BASEL CONVENTIONQuestion & Answer
 Description: Basel Convention sets broad criteria for importing and exporting wastes on participating governments. Convention prohibits shipments of hazardous waste between Basel parties and non-parties, unless they enter separate bilateral or multilateral agreements. United States is not party to Convention, but has bilateral agreements with Canada, Mexico, Malaysia, and Costa Rica and multilateral agreement with OECD members. Basel Ban bars shipments of hazardous waste from developed countries to less-developed countries (SEE ALSO: 64 FR 44722; 8/17/99).
 
09/21/1999HAZARDOUS WASTE IMPORTS FROM TAIWANMemo
 Description: Unless an international agreement prohibits the movement of hazardous waste between the United States and another country, such trade may occur. The United States is not prohibited by agreement from accepting waste from Taiwan. Hazardous waste imported into the United States is immediately subject to the full body of applicable RCRA regulations.
 
08/19/1999SHIPMENTS OF HAZARDOUS WASTE FROM TAIWANMemo
 Description: EPA supports legislation that will enable the United States to become a party to the Basel Convention. EPA believes that as long as waste imported into the United States is managed according to U.S. standards, it will be environmentally protective. EPA believes that given the cost of transportation from foreign countries and the cost of disposal in the United States, it is unlikely that we will experience significant increases in waste imports.
 
08/01/1998IMPORTED HOUSEHOLD WASTEQuestion & Answer
 Description: Imported household hazardous waste is excluded from the definition of solid hazardous waste in the same way as domestically generated household hazardous waste. U.S. importers may be required to fulfill certain obligations if the exporting country or the importer's contract with the exporter requires it. U.S. importers may want to keep records of the foreign exporter should questions arise as to the status of the waste.
 
01/01/1998SHIPMENTS OF HAZARDOUS WASTE FROM THE ISLAND OF MIDWAYQuestion & Answer
 Description: Shipments of hazardous waste from the the island of Midway to the contiguous United States are not subject to the import regulations. The island of Midway is a territory of the United States and is not a foreign country.
 
08/18/1997DRAFT BILATERAL AGREEMENT GOVERNING TRANSBOUNDARY MOVEMENTS OF HAZARDOUS WASTES FROM COSTA RICA TO THE UNITED STATESMemo
 Description: Background and details of the draft import agreement between the United States and Costa Rica. The Intel Corporation approached EPA to pursue a bilateral agreement to allow import of hazardous waste which they expect to generate at a future Intel facility in Costa Rica. Since Costa Rica is a party to the Basel Convention and the U.S. is not, a bilateral agreement governing this trade is necessary for Costa Rica to uphold its Basel obligations.
 
12/11/1996IMPORT OF COAL ASH BYPRODUCT INTO THE UNITED STATESMemo
 Description: Coal ash byproduct consisting of fly ash waste, bottom ash waste, slag waste, and flue gas emission control waste generated primarily from the combustion of coal that has not been mixed with any other material would be exempt under the Bevill exclusion. Importation of such material would not be subject to the import requirements. Coal ash with PCB levels below 50 ppm would not be subject to the TSCA PCB import requirements.
 
06/17/1996RCRA HAZARDOUS WASTE IMPORT REQUIREMENTSMemo
 Description: Parties to the Basel convention cannot trade in hazardous wastes with non-parties in the absence of a bilateral agreement. Singapore is a Basel party while the U.S. is not, nor do these countries have an import/export agreement. EPA regulations do not prohibit imports of hazardous waste. Imported waste is regulated in the same manner as hazardous waste generated in the U.S.. Facilities receiving waste from a foreign source must notify EPA in writing at least four weeks prior to receiving the first shipment of waste.
 
03/07/1996FEDERAL POLICY ON SEVERAL ISSUES RELATED TO THE USE OF THE HAZARDOUS WASTE MANIFEST BY HAZARDOUS WASTE TRANSPORTERSMemo
 Description: The transporter block on the manifest is used to identify companies that transport waste. Transfer facilities do not need to be identified on the manifest unless the owner of the transfer facility takes custody of the waste as a new transporter. Brokers, transporters, or TSDFs may be an importer and therefore subject to generator requirements. One party should assume the generator responsibilities. Discusses the procedures for handling rejected shipments of hazardous waste exported to Canada.
 
02/15/1996EPA'S NON-OBJECTION TO IMPORTS OF COBALT OXIDE-MOLYBDIC OXIDE SPENT CATALYSTS INTO THE U.S. FOR RECOVERYMemo
 Description: Cobalt oxide-molybdic oxide spent catalysts are usually nonhazardous, but can exhibit the toxicity characteristic for benzene and arsenic. EPA does not have the authority to object to imports of nonhazardous waste. In order for Basel parties to export covered waste to non-Basel parties, the two parties must have a bilateral agreement in place. Presents a list of countries that are parties to Basel as of January 10, 1996.
 
11/30/1995SAFE MANAGEMENT OF FLUORESCENT LAMPSMemo
 Description: EPA agrees that it is important to support the goals of the Green Lights Program. EPA received over 300 comments on the proposed mercury-containing fluorescent lamp rule (59 FR 38288; 7/27/94) (SEE ALSO: 64 FR 36466; 7/6/99). States can add lamps to their own lists of universal wastes and set regulatory controls. States may have more stringent laws and policies than the federal program.
 
03/01/1995SIGNING THE MANIFEST AS AN AGENT WHEN IMPORTING HAZARDOUS WASTEQuestion & Answer
 Description: An agent signing the manifest must be legally affiliated with the EPA ID number on the manifest. Foreign brokers can sign the manifest if they have an EPA ID number (requiring U.S. address) or are legally related to the importer (e.g., a subsidiary).
 
02/01/1995INTERNATIONAL AGREEMENTS AND HAZARDOUS WASTE EXPORT REGULATIONSQuestion & Answer
 Description: If EPA has not promulgated implementing regulations, importers and exporters are not subject to international agreements. Canadian and Mexican bilateral agreements are similar to Part 262, Subpart E, so no regulations are needed. EPA will promulgate regulations implementing the OECD agreement.
 
01/01/1995MANIFEST REQUIREMENTS FOR IMPORTED HAZARDOUS WASTEQuestion & Answer
 Description: Multiple parties may be considered importers (TSDF, broker, etc.). When more than one importer exists, they may decide among themselves who will act as the importer and whose ID number will be used. All parties are liable for compliance with RCRA regulations.
 
12/23/1994HAZARDOUS WASTE DETERMINATION OF ""NICKEL MATTE"" BY-PRODUCTMemo
 Description: Nickel matte being reclaimed in China may be solid waste if it will be used in manner constituting disposal. A Basel Convention party may not import Basel-covered waste from non-parties.
 
12/16/1994BUBBLER CANISTERS CONTAINING PHOSPHOROUS OXYCHLORIDE ARE NOT WASTE WHEN RETURNED TO THE UNITED STATES FROM JAPAN FOR REGENERATIONMemo
 Description: Bubbler canisters containing unused phosphorous oxychloride is a commercial chemical product (CCP) when reclaimed and not solid waste. A partially empty bubbler canister which is recharged by adding new phosphorous oxychloride to residual phosphorous oxychloride left in the bubbler is continued use of a product, not waste. The bubbler canister is not subject to OECD provisions when imported into U.S. for reclamation, because the bubbler canister is not subject to U.S. laws and regulations. Phosphorous oxychloride is highly corrosive and reacts violently with water, and therefore could be a reactive or corrosive characteristic hazardous waste if it is a solid waste. It is inappropriate to discharge untreated phosphorous oxychloride to a wastewater treatment system or to land dispose. Phosphorous oxychloride is hazardous reactive (D003) and possibly corrosive (D002) when discarded. Phosphorous oxychloride can be destroyed through the addition of a sodium hydroxide solution.
 
11/28/1994COMMENTS ON NRC’S FINAL RULE AMENDING NRC IMPORT/EXPORT REGULATIONSMemo
 Description: The Basel Convention currently prohibits the movement of hazardous or mixed waste between the U.S. and any nation party to the Convention, unless a pre-existing agreement between the countries exists. Basel Convention restrictions extend to wastes destined for certain types of recycling.
 
09/15/1994National Biennial RCRA Hazardous Waste Report (Based on 1991 Data): National AnalysisPublication
 Description: Analyzes the generation, management, and final disposition of RCRA hazardous wastes, as reported in EPA's 1991 biennial report. Includes waste generation, waste management, shipments and receipts, and imports and exports. Appendices contain system type codes and EPA hazardous waste codes.
 
09/15/1994National Biennial RCRA Hazardous Waste Report (Based on 1991 Data): State Detail AnalysisPublication
 Description: Provides a detailed look at waste handling in EPA regions, states, and at the largest facilities in the nation. Includes quantities of generation, management, shipments and receipts, and interstate imports and exports of RCRA hazardous wastes.
 
09/12/1994RESPONSE TO REQUEST FOR NO OBJECTION TO IMPORT OF IRON CATALYSTMemo
 Description: No regulatory restrictions exist on importing secondary materials not meeting the U.S. definition of hazardous waste, provided the exporting nation also does not consider the material to be hazardous. The Basel Convention prohibits the transfer of hazardous waste between parties and non-parties, unless a separate agreement exists.
 
08/09/1994COMMENTS ON STRAWMAN PROPOSAL REGARDING CUSTOMS MODERNIZATION ACTMemo
 Description: All imports and exports of hazardous waste arriving at a Customs port must be accompanied by a hazardous waste manifest. EPA Acknowledgement of Consent must accompany hazardous waste exports. Under a Memorandum of Understanding (MOU) between EPA and the U.S. Customs Service, the U.S. Customs Service collects the manifest from the exporter and transmits it to EPA.
 
08/09/1994STATUS OF MEDIAL WASTE UNDER RCRAMemo
 Description: Medical waste is not regulated as a hazardous waste under RCRA unless it exhibits a characteristic or is listed. Notification and consent for import or export of hazardous wastes is not required for medical wastes that are not hazardous (SEE ALSO: 60 FR 33912; 6/29/95).
 
07/08/1994EXPORT FROM JAPAN OF PHOSPHORUS OXYCHLORIDE CONTAINING BUBBLERSMemo
 Description: Waste bubblers containing phosphorous oxychloride may exhibit the characteristics of corrosivity (D002) and reactivity (D003). An importer of waste is responsible for hazardous waste determinations and generator duties. An importer could be a waste broker, transporter, or destination TSDF (SUPERSEDED: RPC# 9/14/94-02).
 
05/16/1994ACCEPTABILITY OF IMPORTING NICKEL-CONTAINING CATALYSTS FOR NICKEL RECOVERY AND STAINLESS STEEL SCRAPMemo
 Description: Nickel-containing catalysts and stainless steel scrap that do not exhibit a characteristic may be imported for recovery because they are not hazardous wastes. The applicability of the Basel Convention and bilateral agreements are discussed.
 
04/18/1994RESPONSE TO REQUEST FOR COMMENT TO IMPORT METAL-BEARING SLUDGEMemo
 Description: A generator retains the burden of proof when claiming an imported material is not a solid waste or is conditionally exempt from regulation. An importer must make a hazardous waste determination on a shipment by shipment basis.
 
03/22/1994REQUIREMENTS FOR MANIFESTING SHIPMENTS OF HAZARDOUS WASTE BY RAIL FROM CANADAMemo
 Description: RCRA Subtitle C regulations can only apply to U.S. parties. The U.S. importer, importer's agent, and transporter may all be generators. All generators are jointly and severally liable for compliance with the generator requirements. Rail shipments of hazardous waste need not be accompanied by a manifest. A generator of waste that is transported solely by rail forwards copies of the manifest directly to the designated facility.
 
03/15/1994Environmental Fact Sheet: Principles for Basel Convention Aim to Prevent Pollution, Reduce Risk, and Promote Recycling Issues recommendations to Congress for implementing the Basel ConventionPublication
 Description: This fact sheet presents recommendations to Congress for implementing the Basel Convention. The recommendations ask Congress to ban the export of nearly all hazardous wastes, municipal wastes, and municipal incinerator ash beyond North American borders, emphasize the principles of waste minimization to make the United States more self-sufficient in the management and disposal of its wastes, and foster appropriate recycling of low hazard materials (e.g., scrap paper, glass, textiles, and scrap metals) that trade like commodities and are needed as raw materials by not limiting transboundary movements of these materials. The fact sheet also lists parties to the Basel Convention as of February 22, 1994.
 
07/15/1993COMMENTS ON DRAFT MEMO OF ORDER BETWEEN EPA AND THE U. S. GOVERNMENT SERVICEMemo
 Description: Addresses the Memorandum of Understanding (MOU) between EPA and U.S. Customs. Importers or transporters are not obligated to submit manifests to U.S. Customs at the border.
 
01/28/1993MOVEMENT OF NICKEL CADMIUM BATTERIES FROM MEXICO TO JAPAN VIA THE UNITED STATESMemo
 Description: Hazardous waste is subject to RCRA within U.S. borders. Hazardous waste imported to the U.S. from Mexico for subsequent shipment to Japan is subject to RCRA requirements the moment that it enters the U.S., including import provisions and export provisions. Used batteries that are sent to a battery manufacturer for regeneration are not subject to the Part 262 export requirements (SUPERSEDED: 261.6(a)(3)(ii) removed, See Part 273 and 60 FR 25535; 5/11/95).
 
08/01/1992ACCUMULATION TIME FOR HAZARDOUS WASTE IMPORTERSQuestion & Answer
 Description: Importers cannot accumulate hazardous waste under Section 262.34 when hazardous waste first enters the United States, even though importers must comply with certain other generator requirements.
 
12/05/1991HAZARDOUS AND MUNICIPAL WASTE IMPORTS AND EXPORTS BETWEEN THE U.S. AND CANADAMemo
 Description: The import of hazardous waste and solid waste is not prohibited under federal regulations. Wastes are "goods in commerce," and protected under the commerce clauses in the Constitution.
 
11/14/1991THE BASEL CONVENTION AND UNTREATED MEDICAL WASTE IMPORTATIONMemo
 Description: There are no federal regulations prohibiting the importation of medical waste. The enactment of legislation implementing the Basel Convention could change the status of imported medical waste (SEE ALSO: 60 FR 33912; 6/29/95).
 
04/27/1989INTERNATIONAL TRANSPORT OF LAB SAMPLESMemo
 Description: Lab samples shipped from Canada are exempt from Subtitle C, including import requirements, per 261.4(d).
 
06/25/1985GENERATOR RESPONSIBILITIES FOR IMPORTATION OF HAZARDOUS WASTEMemo
 Description: The importer is the generator. The transporter and the U.S. facility arranging the import are importers and cogenerators. There is joint and several liability for generators and cogenerators. Imported hazardous waste (HW) must be manifested. Imported HW is subject to all applicable manifest requirements even if the importer and TSDF are the same.
 
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