HAZARDOUS WASTE EXPORT PROCESS
Many waste generators that believe exporting their hazardous or non-hazardous waste is possible, still think the process is difficult and time consuming. Generators that believe you simply can't export hazardous waste out of the country, just don't know have all the facts.
Fear that exporting their hazardous waste will come back to bite them, tends to leave a lot of waste generators fearful of even approaching the subject. Others just want to place their heads in the sand, like our fella to the right, and refuse to even talk about the possibilities. Questions like, "Is it really legal to export my waste," or "I still have all the liability, right?" are questions that surface quite often.
Exporting hazardous and non-hazardous waste out of the United States is a process that has fallen into the "I can't believe it's true," category. However, the reality of the export process is very similar to the process waste generators already use in the U.S. We'll explain the entire process and how it is possible to export your waste out of the country and actually save you money in the process.
How Did Temarry Get Permission?
All of the requirements to legally export your hazardous waste to Mexico have already been completed by Temarry Recycling, Inc. The authorization process started with a Notice of Intent that was sent to the EPA per the requirements of 40 CFR 262 Subpart E. An Acknowledgement of Consent (AOC) was granted, and continues to be granted every year, to Temarry by the EPA. This AOC is the document that gives Temarry the legal authority to accept certain waste streams into Mexico. A copy of the AOC will accompany each export and become part of the export package.
The Export Process
For the generator, the process from this point is very similar to sending waste to any other facility in the United States.
These are the steps:
Your hazardous waste service company will assist you in completing a waste profile. This is the generators description of what waste is being disposed of. The profile will be signed by you the generator or your representative. Your service company will submit the profile to Temarry for approval. Approval process typically takes 3-5 days but can be faster if needed.
After Temarry has approved the profile, an Acceptance Letter (AL) will be sent to the service company. The AL will have the waste category code based on the profile information and a profile number issued by Temarry. The AL is signed and returned to Temarry.
A waste pick up can now be scheduled with the hazardous waste service company. The service company will prepare the Uniform Hazardous Waste Manifest or other appropriate shipping paper. This is the same Manifest used for all domestic shipments in the United States. The differences are that in block 14 it will say, “Primary Exporter:
Temarry Recycling, Inc.” In block 16 the transporter will mark the “Export from U.S.” box and write in the appropriate Port of entry/exit.
On the day of export the date will be filled in by the transporter. A shipping copy of the manifest will be left with the generator.
Typically, about 1 hour after the load clears U.S and Mexican Customs the load arrives at the Temarry facility located in Tecate, B.C., Mexico.
Within one day after the load is received each container is inspected and sampled according to Temarry protocol. For solid waste, technicians will do a visual inspection and probe. For liquid waste technicians will check specific gravity, pH and sludge content. Technicians will complete a Waste Categorization Report and send it to customer service along with the manifest.
Customer service will confirm that the waste conforms to the profile. Any discrepancies will be reported to the hazardous waste service company. Customer service will apply the appropriate Handling Codes in block 19 and Designated Facility signature in block 20.
The generators copy of the Manifest will be sent directly to the generators mailing address listed on the manifest along with a Certificate of Recycling. Documents are sent to the generator and service company via First Class mail in a specially designed envelope.
When the generator receives a copy of the Manifest with the Facility signature on it the process is complete.
As you can see from the outlined process, it is very similar to what waste generators are already using in the U.S. One of the main advantages of exporting your waste streams out of the U.S., is a reduction in your company's carbon footprint and the cost savings you will receive by utilizing a TSDF facility that provides True Recycling, while achieving the highest level of sustainability available.