How to Legally Transport Your Hazardous Waste to Mexico
The notion that you could legally transport any form of waste let alone hazardous waste into Mexico, for most generators or transportation companies, was a myth for many years.
It’s Illegal, Right?
The thought process, that many waste generators envisioned, is seeing their waste streams being hauled down to Mexico and being dumped into landfills or at worst local communities. No environmental protections or agencies overseeing the recycling process, corruption and lack of accountability were common perceptions that many waste generators and hazardous waste transportation companies had. Not to mention that most people thought the transportation of hazardous waste to Mexico was illegal in the first place.
Their ultimate cradle to grave nightmare coming true!
However, the real truth is quite different. It is not only possible to legally transport hazardous waste into Mexico for recycling, but in many cases it is often cheaper, safer and has a lower environmental impact than other methods of disposal.
How is it Possible?
For over 17 years, Temarry Recycling has had the legal authority, given to them by the US Environmental Protection Agency (EPA) and the Government of Mexico, to legally transport RCRA, Non-RCRA and non-hazardous waste to their facility in Tecate, B.C. Mexico.
The EPA issued an Acknowledgement of Consent (AOC) to Temarry that certifies to the waste generator that the EPA has done their due diligence to confirm with the government of Mexico that Recicladora Temarry has all necessary permits, is in good standing, and is authorized to receive listed imported waste. Temarry Recycling must submit a new Notice of Intent (NOI) every year to EPA to request that a new AOC be granted for the following year.
Export Notification Diagram
Who Has the Liability?
An often misunderstood practice of moving hazardous waste streams into Mexico is the issue of liability. As a US generator of waste, the “cradle to grave,” process has been the standard by which each generator measures its share of liability. Waste generators in the United States have always known that they are responsible for their waste from the moment it leaves their facility until it is disposed of or recycled at a TSDF facility.
However, when transporting hazardous waste into Mexico, through Temarry Recycling, the waste generators liability for that waste ends at the US border. From the moment the waste crosses the border into Mexico, the waste generators liability ends. At the border Temarry Recycling becomes the Principal Responsible Party in the U.S. and Recicladora Temarry de Mexico accepts generator liability in Mexico. Waste arrives at the facility the same day that it is imported. After acceptance, handling codes are applied in block 19 and signed as received in block 20 of the U.S. manifest. Generator copy of the manifest is returned directly to the generator within 30 days of receipt of the waste by Recicladora Temarry.
Why should you Transport Your Hazardous Waste to Mexico?
Certain waste streams like:
- Flammable solvents including alcohols
- Paint related materials
- Flammable mixtures with and without halogens
Or most organic solids with fuel value. Non RCRA waste including oils, oily water, antifreeze and latex paint, can be processed by Temarry in a very cost effective manner. All waste is processed on site receiving an H020 handling code for distillation or an H050 handling code for, “energy recovery at this site”.
Shipping these types of waste streams to other parts of the country, is not only cost prohibitive, but creates a much larger carbon footprint than is necessary.
Carbon Footprint Calculation
Since Temarry Recycling is one of only a few facilities that can recycle flammable liquids for reuse, making sure your waste ends up here is not only more cost effective, but dramatically reduces the amount of carbon footprint left behind.
Temarry recycles expensive solvents by distillation that are sold back into industry for reuse, thereby eliminating the need for costly disposal or inefficient fuel blending.