Frequent Questions

Are ocean carriers transporting hazardous waste required to obtain EPA identification (ID) numbers? Are uniform hazardous waste manifests required for international shipments of hazardous wastes?

An EPA ID number is not required once a hazardous waste is outside of US jurisdiction (Memo, Petruska to Lassner; February 17, 1995 (RCRA Online #11894). This is because an EPA ID number typically is not required if the transporter is not required to have a RCRA manifest accompanying the waste (Memo, Cotsworth to Huffman; April 17, 2002 (RCRA Online #14595). For international exports from the US, tranpsorters who transport hazardous waste out of the US are required to give a copy of the manifest to the US Customs Service officials at the point of departure from the US (Part 263.20(g)(4)). When ocean carriers enter US territorial seas to unload hazardous waste cargo at coastal ports, a manifest is not required before the hazardous waste shipment is unloaded at th US port. Since EPA does not require a hazardous wase manifest for ocean carriers in US territorial seas when they are importing or exporting, ocean carriers transporting hazardous waste are not required to obtain an EPA ID number (Memo, Cotsworth to Huffman; April 17, 2002 (RCRA Online #14595). 

Additional guidance on ocean carriers transporting hazardous wastes cargo, EPA ID numbers and manifest requirements is available in the following memos: 

Memo, Cotsworth to RCRA Senior Policy Managers; December 4, 2001 (RCRA Online #14580)
Memo, Shapiro to Stokcer; March 4, 1994 (RCRA Online #11816
Memo, Clay to Hekman; December 3, 1990 (RCRA Online #11571

These memos are available at the following URL:

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