Memo Detail

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RCRA Online Number: 14922
Title: APPLICABILITY OF HAZARDOUS WASTE IMPORT AND EXPORT REQUIREMENTS TO INTERNATIONAL OCEAN CARRIERS
Document Date: 2019-02-11
To: Currie
From: Johnson
Organization of Recipient: International Vessel Operators Dangerous Goods Association
Description: An EPA ID number is not required if the transporter is not required to have a manifest. 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. The ocean carrier remains subject to other applicable requirements (e.g., Department of Transportation (DOT) regulations) (SEE ALSO RCRA Online number 14595). But under the Hazardous Waste Export-Import Revisions Final Rule (see 81 FR 85696, November 28, 2016) that became effective on December 31, 2016, the movement document requirements and transporter requirements to notify in cases where an incident during transit requires the return or alternate management of the hazardous waste import or export shipment do apply to international ocean carriers in territorial waters carrying hazardous waste import and export shipments.
Regulatory Citation(s): 262.84(f)(2)(ii), 262.83(f)(3)(i), 262.83(d), 262.84(f)(3), 262.84(f)(4)(i), 262.84(f)(7) , 262.83(f)(2)(ii), 262.84(d)(xiii), 262.83(f)(8)
Official ORCR Policy: Yes
Associated Topic(s): Exports, Imports, Transporters