Contents Notes |
I. Introduction -- II. Summary -- III. Applicable regulations -- IV. EPA enforcement strategy -- V. Development of procedures -- VI. Training -- VII. Waste exporter profiles -- VIII. Border spot checks -- IX. Coordination/responsibilities -- Appendix A. Section 3017 of RCRA -- Appendix B. RCRA export regulations -- Appendix C. International agreement with Canada -- Appendix D. International agreement with Mexico -- Appendix E. Customs/EPA memorandum of understanding This Customs/EPA Joint Enforcement Strategy is designed to ensure that all exports of hazardous waste from the United States are in compliance with applicable statutes and regulations and that the exports are reported to EPA. Compliance of import shipments of hazardous waste is also monitored. Enforcement activities are national in scope with emphasis on 10-20 ports of exit in New England, New York, Michigan and Washington and along the Mexican border which are known to handle hazardous waste shipments. Regulations applicable to the transport and handling of hazardous waste are complex. This strategy focuses on ensuring that all transboundary shipments of hazardous waste are accompanied by the proper documentation and that the shipments have been consented to by the receiving country. Key documents are the EPA Uniform Hazardous Waste Manifest (a shipping paper that identifies the exporter, transporter and receiving facility and that describes the nature and volume of the waste) and, for exports, the EPA Acknowledgment of Consent that authorizes the shipment. EPA has implemented an overall enforcement strategy for the regulation of hazardous waste exports. Activities conducted as part of the Customs/EPA Joint Enforcement Strategy form an integral part of the overall strategy. Elements of the EPA strategy include a program to inform the regulated community, information management activities, an inspection strategy and enforcement response procedures. |