Memo Detail

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RCRA Online Number: 14595
Title: APPLICABILITY OF TRANSPORTER REQUIREMENTS TO HAZARDOUS WASTE IMPORTS AND EXPORTS
Document Date: 2002-04-17
To: Huffman
From: Cotsworth
Organization of Recipient: Criterion Catalysts & Technologies
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.
Regulatory Citation(s): 263.20(g)(4), 263.11, 263.10
Official ORCR Policy: Yes
Associated Topic(s): Exports, Generators, Imports, Transporters