SUPPORTING STATEMENT FOR

EPA INFORMATION COLLECTION REQUEST NUMBER 2308.02

Revisions to the Requirements for Transboundary Shipments of Wastes between OECD 

Countries, the Requirements for Export Shipments of Spent Lead Acid Batteries, the 

Requirements on Submitting Exception Reports for Export Shipments of Hazardous 

Wastes, and the Requirements for Imports of Hazardous Wastes

FINAL

December 2009

Office of Resource Conservation and Recovery

United States Environmental Protection Agency

Washington, D.C. 20460
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TABLE OF CONTENTS

1. IDENTIFICATION OF THE INFORMATION COLLECTION . . . . . . . . . . . . . 3

1(a) Title and Number of the Information Collection . . . . . . . . . . . . . . . . . . . . 3

1(b) Short Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

2. NEED FOR AND USE OF THE COLLECTION . . . . . . . . . . . . . . . . . . . . . . . . .8

2(a) Need and Authority for the Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

2(b) Practical Utility and Users of the Data . . . . . . . . . . . . . . . . . . . . . . . . . . . .9

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

3(a) Nonduplication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9

3(b) Public Notice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

3(c) Consultations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

3(d) Effects of Less Frequent Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

3(e) General Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11

3(f) Confidentiality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

3(g) Sensitive Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11

4. THE RESPONDENTS AND THE INFORMATION REQUESTED . . . . . . . . . 11

4(a) Respondents and SIC/NAICS Codes . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

4(b) Information Requested . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, 

COLLECTION METHODOLOGY, AND INFORMATION 

MANAGEMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .23

5(a) Agency Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

5(b) Collection Methodology and Management . . . . . . . . . . . . . . . . . . . . . . . 24

5(c) Small Entity Flexibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

5(d) Collection Schedule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION . 25

6(a) Estimating Respondent Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

6(b) Estimating Respondent Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

6(c) Estimating Agency Burden and Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

6(d) Estimating the Respondent Universe and Total Burden and Costs . . . . . 28

6(e) Bottom Line Burden Hours and Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

6(f) Reasons for Change In Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

6(g) Burden Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
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1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

This information collection request (ICR) is entitled "Revisions to: the 

Requirements for Transboundary Shipments of Wastes between OECD Countries, the 

Requirements for Export Shipments of Spent Lead Acid Batteries, the Requirements on 

Submitting Exception Reports for Export Shipments of Hazardous Wastes, and the 

Requirements for Imports of Hazardous Wastes," EPA ICR Number 2308.01.

1(b) Short Characterization 

The U. S. Environmental Protection Agency (EPA) is promulgating a final action 

to amend the existing regulations governing shipments (export/import/transit) of 

hazardous wastes destined for recovery between the U.S. and the Organization for 

Economic Cooperation and Development (OECD) countries. The action integrates into 

the Code of Federal Regulations (CFR) various OECD Council Decisions1revising the 

rules governing transboundary movement of hazardous wastes among OECD countries, 

which the U.S, as a signing party, is obligated to implement. In order to implement this 

legally-binding obligation, EPA is taking action to amend the existing regulations at 40 

CFR 262, subpart H. EPA is also taking this opportunity to make technical corrections 

and clarifications to the regulations at 40 CFR part 262; §262.10(d); §262.58(a); 

§262.58(b); §263.10(d); §264.12(a)(2); and §265.12(a)(2). The Agency’s regulatory

changes do not increase the scope of hazardous wastes subject to U.S. export and import 

controls. However, they modify the procedural controls governing U.S. export and 

import of hazardous waste shipped for recovery operations among OECD Member 

countries (except for Canada and Mexico). Hazardous waste shipments to Canada and 

Mexico will continue to move under the current bilateral agreements and regulations.

As part of this final action, EPA is also regulating exports of Spent Lead-Acid 

Batteries (SLAB) to OECD countries (except for Canada and Mexico) under the same 

rule above (40 CFR 262, subpart H) while regulating SLAB exports to non-OECD 

countries (including Canada and Mexico) under 40 CFR 262, subpart E requirements. 

(Currently, SLABs are exempt from any export requirements when managed under 40 

CFR 266 subpart G ("SLAB Regulations"). SLABs may also be managed as Universal 

Wastes under 40 CFR 273 ("Universal Waste Regulations") under which specific export 

requirements apply; however, very few exporters have chosen to do so.) Specifically, 

exporters of SLABs destined for reclamation in one of the OECD Member countries 

listed in § 262.58(a)(1) would be required to comply with the Amber control procedures 

in §262.83. Under the Amber control procedures, an exporter must submit a complete 

notification of its intent to export to EPA at least 45 days before the export is scheduled 

to leave the United States (or at least ten days if the shipment is going to a pre-approved 

 

1 OECD’s “Decision of the Council C(2001)107/FINAL, Concerning the Control of Transboundary 

Movements of Wastes Destined for Recovery Operations, as amended by C(2004)20” (hereinafter referred 

to as the Amended 2001 OECD Decision), which amended the OECD Decision (1992) on the same subject.
4

facility in the country of import). Exporters of SLABs destined for reclamation in 

countries not listed in §262.58(a)(1) would be required to comply with the primary

exporter notification requirements in §262.53, and export the SLABs only upon consent 

of the receiving country and in conformance with the EPA Acknowledgement of Consent 

as defined in 40 CFR part 262, subpart E. 

Also incorporated into this action is a requirement for documentation necessary to 

confirm EPA’s consent to import. Specifically, U.S. receiving facilities must match 

EPA-provided import consent documentation to incoming hazardous waste import 

shipments and submit to EPA a copy of the relevant import consent documentation 

(along with a copy of the RCRA hazardous waste manifest currently required) within 

thirty days of each import shipment delivery. These changes modify the language in 

§264.71(a)(3), and §265.71(a)(3). 

Finally, this action revises the current language in §262.55 and §262.87(b) to 

specify that exception reports be submitted directly to the Director, International 

Compliance and Assurance Division (ICAD), of the Office of Enforcement and 

Compliance Assurance (OECA), EPA Headquarters, rather than to the EPA 

“Administrator.” 

REGULATORY CHANGES/AMENDMENTS

A. Changes to 40 CFR part 262, subpart E

The final rule amends the exception reporting requirements in §262.55 to specify

that all exception reports be submitted to the Office of Enforcement and Compliance 

Assurance’s Office of Federal Activities in Washington, D.C. rather than to the 

Administrator. In addition, the rule updates §262.10(d) and §262.58(a) to reflect that 

export shipments of SLABs being managed under 40 CFR part 266, subpart G that are 

destined for recovery in one of the OECD Member countries listed in §262.58(a)(1) are 

subject to the requirements of subpart H. Finally, the rule adds language in §262.58(b) of 

subpart E to clarify that hazardous waste exports subject to subpart E and hazardous 

waste imports subject to subpart F are not subject to subpart H in order to reduce 

confusion for U.S. exporters and importers. 

B. Changes to 40 CFR part 262, subpart H 

All but the last three of the changes listed below are necessary to conform to the 

revisions in the Amended 2001 OECD Decision. These changes range from substantive 

revisions and amendments to changes in terminology to simple editorial changes. 

Collectively, these changes serve to implement the Amended 2001 OECD Decision, as 

well as clarify certain sections that were previously ambiguous to the regulated 

community. Changes to 40 CFR part 262, subpart H include the following:

(1) Changes in terminology
5

The final rule adopts several terms and definitions updated in the Amended 

2001 OECD Decision to limit any unnecessary confusion between the U.S. 

regulations and those of other OECD Member countries and to promote 

consistency with the Amended 2001 OECD Decision.

(2) The number of different levels of control reduced from three (Green, 

Amber, and Red) to two (Green, Amber) and the waste lists updated

Both the Green and Amber waste lists are cited in §262.89. The final rule 

amends §262.89(d) to incorporate by reference the most current OECD waste 

lists from the Amended 2001 OECD Decision. All wastes formerly appearing 

on the Red list will be subject to the Amber control procedures.

(3) References to unlisted wastes eliminated in favor of “wastes not covered 

in Appendices 3 and 4 of the OECD Decision”

The rule replaces the term “unlisted wastes” currently used in §262.83(d) with 

“wastes not covered in Appendices 3 and 4 of the OECD Decision,” so that 

wastes not on these lists are not subject to the Amber control procedures. The

rule also renumbers §262.83(d) to §262.83(c) since the current §262.83(c) 

addresses “red-list wastes” and is no longer needed. 

(4) Transboundary movements may now qualify for a laboratory analysis 

exemption

The final §262.82(g) allows for waste samples that are sent for laboratory

analyses to be exempt from the Amber control procedures provided they meet 

the same conditions as set forth in the Amended 2001 OECD Decision. Such 

analytical samples must still be appropriately packaged and labeled.

(5) Recovery facilities must submit a certificate of recovery

The final rule incorporates the certificate recovery provisions of the Amended 

2001 OECD Decision in §262.83(e) (while the current §262.83(e) on 

notification requirements is renumbered to §262.83(d), as addressed below).

The final rule requires that the recovery facility must send copies of the 

certificate of recovery to the exporter and competent authorities of the 

countries of export and import by mail, e-mail followed by mail, or fax 

followed by mail. 

(6) Amendments to notification requirements

The final rule amends §262.83(e) (and renumbers to §262.83(d)) by

incorporating several new OECD notification requirements, including: 

exporter and importing recovery facility e-mail address; e-mail address for 

importer (if different from the importing recovery facility); address, 
6

telephone, fax, and e-mail address of intended transporter(s); means of 

transport envisioned; and specification of the type of recovery operation(s) 

that will be used, according to §262.81.

(7) The consideration period for transboundary movements to pre-approved 

facilities has been reduced and the allowable notice coverage period has 

been increased

The final rule amends §262.83(b)(2)(ii) to reflect the Amended 2001 OECD 

Decision to reduce the consideration period to seven (7) working days, which 

can be extended to thirty (30) days by the competent authority in exceptional 

cases. The final rule also amends §262.83(b)(2)(i) to reflect the Amended 

2001 OECD Decision to increase the allowable notice coverage period for 

general notifications to three (3) years.

(8) New procedures for the pretreatment of hazardous wastes at R12/R13 

recovery facilities

The final rule incorporates the new requirements imposed by the Amended 

2001 OECD Decision for transboundary movements of wastes destined for

R12 and R13 recovery operations (transfer and accumulation, respectively)2

in §262.82(f).

(9) New provisions regarding mixtures of hazardous wastes

The final rule revises the text in §262.82(a) to clarify that only those wastes 

and waste mixtures considered hazardous under U.S. national regulations will 

be subject to the Amber control procedures within the United States.

(10) New provisions regarding the return and re-export of hazardous wastes 

subject to the Amber control procedures

The final rule sets forth the re-export and return provisions of the Amended 

2001 OECD Decision in §§262.82(c), 262.82(d), and 262.82(e), on measures 

to be taken in case a transboundary movement of hazardous waste that is 

subject to the Amber control procedures cannot be completed as intended.

(11) SLABs are now covered by EPA’s OECD rule

The final rule updates §262.80(a) to reflect that export shipments of SLABs 

being managed under 40 CFR part 266, subpart G that are destined for 

recovery in one of the OECD countries listed in §262.58(a)(1) are subject to 

40 CFR part 262, subpart H. 

 

2 R12 is defined in §262.81 as exchange of wastes for submission to any of the operations numbered R1-

R11. R13 is defined in §262.81 as accumulation of material intended for any operation numbered R1-R12.
7

(12) Technical Corrections to EPA’s OECD rule

The final rule makes several technical corrections to EPA’s current OECD 

rule, including corrections to capitalization, syntax, and punctuation errors. In 

these changes, EPA is not making any substantive revisions, but is seeking to 

eliminate any confusion on the part of the regulated community by striving for 

consistency both within the regulations and with the terms of the Amended 

2001 OECD Decision. 

(13) Change to the submittal address for exception reports

The final rule amends the exception reporting requirements in §262.87(b) to 

specify that all exception reports are to be submitted to the Office of 

Enforcement and Compliance Assurance’s Office of Federal Activities in 

Washington, D.C. rather than the Administrator. 

C. Changes to 40 CFR 263.10(d)

The final rule updates §263.10(d) to reflect that export shipments of SLABs being 

managed under 40 CFR part 266, subpart G that are destined for recovery in one of the 

OECD countries listed in §262.58(a)(1) are subject to 40 CFR part 262, subpart H.

D. Changes to 40 CFR 264.12(a)(2) and 40 CFR 265.12(a)(2)

The final rule amends §§264.12(a)(2) and 265.12(a)(2) by, among other things, 

requiring owners or operators of recovery facilities to submit a certificate of recovery as 

soon as possible after the recovery is completed, but no later than thirty (30) days after 

the completion of recovery and no later than one (1) calendar year following the receipt 

of the hazardous waste. 

E. Changes to 40 CFR 264.71 and 40 CFR 265.71

The final rule amends §§264.71(a)(3) and 265.71(a)(3) by requiring owners or 

operators of facilities receiving imported hazardous wastes to submit to EPA the written 

documentation of EPA’s consent to the import along with a copy of the RCRA hazardous 

waste manifest for the shipment that they are currently required to submit to EPA within 

thirty (30) days of shipment delivery. This will enable EPA to match the individual 

shipment manifest to the consent for an annual notice from a foreign exporter. In 

addition, the rule also updates §§264.71(d) and 265.71(d) to reflect the current address 

for the Office of Enforcement and Compliance Assurance’s Office of Federal Activities 

in Washington, D.C.

F. Changes to 40 CFR 266.80(a)

The existing regulations at 40 CFR part 266, subpart G, “Spent Lead-Acid 

Batteries Being Reclaimed,” exempt exporters of SLABs destined for reclamation from 
8

the export requirements of 40 CFR part 262. EPA is amending the table located at 

§266.80 by including two additional rows to the current table. These additional rows will 

effectively require that exporters and transporters of SLABs being sent to a foreign 

country for reclamation will need to meet the universal waste requirements concerning 

the export of SLABs for reclamation. Specifically, exporters will need to either comply 

with the requirements in 40 CFR part 262, subpart H when the shipments are destined to 

one of the OECD Member countries listed in §262.58(a)(1), or with relevant 

requirements in 40 CFR part 262, subpart E when the shipments are destined for any 

country not listed in §262.58(a)(1).

G. Changes to 40 CFR 271.1

This final rule amends Table 1 and Table 2 of §271.1 by adding references to the 

revisions which amend 40 CFR part 262, subpart E to reflect that subpart E implements 

the Hazardous and Solid Waste Amendments of 1984.

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need and Authority for the Collection

EPA is promulgating the above regulatory changes/amendments under the 

authority of Sections 1006, 1007, 2002(a), 3001-3010, 3013-3015, and 3017 of the Solid 

Waste Disposal Act, as amended by the Resource Conservation and Recovery Act 

(RCRA), and as amended by the Hazardous and Solid Waste Amendments, 42 U.S.C. 

6905, 6906, 6912, 6921-6930, 6934, and 6938.

The final rule is intended to implement the Amended 2001 OECD Decision, 

which amended the OECD Decision (1992)3on the same subject. The purpose of these 

revisions was to encourage consistency and harmonization between the OECD and the 

Basel Convention,

4 which in turn, promotes economic efficiency and the recovery of 

 

3 On March 30, 1992, the OECD Council adopted the “Decision of the Council C(92)39/FINAL 

Concerning the Control of Transfrontier Movements of Wastes Destined for Recovery” (hereinafter 

referred to as the 1992 Decision), which applied to the transboundary movements of wastes destined for 

recovery operations between OECD Member countries. The 1992 Decision provided a framework for 

OECD Member countries to control the transboundary movement of recoverable wastes in an 

environmentally sound and economically efficient manner. Due to the legally binding nature of the 1992 

Decision, the United States, as an OECD Member country, was required to implement the terms of the 

decision in accordance with Articles 5(a) and 6(2) of the OECD Convention. In order to implement the 

specific provisions of the 1992 Decision, EPA published a final rule in the FEDERAL REGISTER entitled 

“Imports and Exports of Hazardous Waste: Implementation of OECD Council Decision C(92)39 

Concerning the Control of Transfrontier Movements of Wastes Destined for Recovery Operations” (61 FR 

16289, April 12, 1996)(hereafter referred to as EPA’s OECD rule). These regulations appear primarily in 

40 CFR part 262, subpart H.

4 The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their 

Disposal is a comprehensive global environmental agreement on hazardous and other wastes. The 

Convention has 172 Member countries, also known as Parties, and aims to protect human health and the 
9

waste in an environmentally sound manner.

The Amended 2001 OECD Decision was supported by the United States and 

imposes legally binding commitments on the United States pursuant to Articles 5(a) and 

6 of the OECD Convention. By consenting to the Decision, the United States 

Government has agreed to promulgate regulations necessary to ensure that the United 

States can uphold the agreement.

2(b) Practical Utility and Users of the Data

The Office of Enforcement and Compliance Assurance, U.S. EPA, uses the

information provided by each U.S. exporter, U.S. importer, and U.S. receiving facility to 

determine compliance with the applicable RCRA regulatory provisions. In addition, the 

information is used to determine the number, origin, destination, and type of exports from 

and imports to the U.S. for tracking purposes and for reporting to the OECD. This 

information also is used to assess the efficiency of the program.

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) Nonduplication

Except as described below, the OECD Decision does not result in the collection of

duplicate data. Although some of the information required for the hazardous waste 

manifest and the movement document is substantively the same, up to six pieces of 

additional information are required for the movement document. In addition, these two 

documents serve different purposes. A signed copy of the hazardous waste manifest, 

which is not valid beyond U.S. borders, is dropped off at the U.S. Customs check point 

when the shipment leaves the U.S. to verify pertinent information, including point of 

departure, date, destination, and contents of the shipment. The movement document must 

accompany the shipment until it reaches the foreign recovery facility. The signed 

movement document is subsequently returned to EPA and the U.S. exporter to 

acknowledge receipt of the shipment in accordance with the OECD Decision.

In certain cases, some of the information on the tracking document also may be

collected by the Department of Commerce in its Census Bureau form titled "Shipper's 

Export Declaration" (15 CFR Part 30). This form, which is required for all shipments 

that have a value in excess of $2,500, must be filed at the U.S. port of exit, similar to the 

current export requirements. However, the information contained in the Census Bureau's 

form is not adequate for EPA's purpose of tracking and identifying the export of 

 

environment against the adverse effects resulting from the generation, management, transboundary 

movements and disposal of hazardous and other wastes. More information on the Basel Convention may 

be found at www.basel.int.
10

hazardous waste from the U.S. For example, the wastes are identified by tariff codes that 

are less precise than the waste codes required by the tracking document.

Because the OECD Decision applies only to hazardous waste destined for 

recovery, it is likely that some of the wastes may have a value in excess of $2,500. EPA 

believes that the economic interest served by allowing recovery operations to continue 

within the OECD and the interest in protecting human health and the environment served 

by the tracking document outweigh the potential minor costs to a small number of 

exporters that may have to complete the Census Bureau form in addition to the tracking 

document.

3(b) Public Notice

Under the Paperwork Reduction Act of 1995, EPA requested public comments on 

the information collection provisions of the proposed rule published in the Federal 

Register on October 6, 2008. Comments had to be received by OMB on or before 

November 5, 2008. No comments on the information collection provisions were 

submitted.

3(c) Consultations

As noted previously, OECD Council Decisions are international agreements that 

create binding commitments on the United States, unless otherwise provided in the 

Articles to the 1960 Convention. Therefore, by consenting to the Amended 2001 OECD 

Decision, the United States Government has agreed to establish legal measures necessary

to ensure that the United States can uphold the agreement. EPA believes that RCRA 

contains adequate authority to promulgate the requirements of the Amended 2001 OECD 

Decision. 

EPA consulted with industry concerning OECD imports and exports in July 2004

and consulted with industry concerning SLAB recycling and export shipments in 1998. 

See Appendix A in “September 1998 Industry Study.pdf,” and “Consultation Telephone 

Logs_092704.pdf” available in the public docket for this rulemaking.

3(d) Effects of Less Frequent Collection

EPA has carefully considered the burden imposed upon the regulated community

by the final regulatory changes/amendments other than those required to implement the 

legally binding obligation of the Amended 2001 OECD Decision. EPA is confident that 

the activities required of respondents are necessary, and to the extent possible, has 

attempted to minimize the burden imposed. EPA believes strongly that if the minimum 

requirements specified under the regulations are not met, EPA can not ensure that 

hazardous wastes are properly managed and do not pose a serious threat to human health 

and the environment.
11

3(e) General Guidelines

This ICR adheres to the guidelines stated in the Paperwork Reduction Act of 

1995, OMB’s implementing regulations, OMB’s Information Collection Review 

Handbook, and other applicable OMB guidance.

3(f) Confidentiality

Section 3007(b) of RCRA and 40 CFR part 2, subpart B, which defines EPA’s 

general policy on public disclosure of information, contain provisions for confidentiality. 

However, the Agency does not anticipate that businesses will assert a claim of 

confidentiality covering all or part of the final rule. If such a claim were asserted, EPA 

must and will treat the information in accordance with the regulations cited above. EPA 

also will assure that this information collection complies with the Privacy Act of 1974 

and OMB Circular 108.

3(g) Sensitive Questions

No questions of a sensitive nature are included in the information collection 

requirements associated with the final rule.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and SIC/NAICS Codes

OECD Revisions

The OECD revisions in this final rule affect all persons who export or import 

hazardous waste, export or import universal waste, or export spent lead-acid batteries 

(SLABs) destined for recovery operations in countries belonging to the Organization for 

Economic Cooperation and Development (OECD), except for Mexico and Canada. Any 

transboundary movement of hazardous wastes between the United States and either 

Mexico or Canada will continue to be regulated by their respective bilateral agreements 

and applicable regulations. Potentially affected entities may include, but are not limited 

to: 

Industry Sector NAICS SIC

Utilities 221100 4939

Petroleum and Coal Products Manufacturing 324 29

Chemical Manufacturing 325100 28

Primary Metal Manufacturing 331 33

Fabricated Metal Product Manufacturing 332 34

Machinery Manufacturing 333 35

Computer and Electronic Product Manufacturing 334110 357
12

Industry Sector NAICS SIC

Electrical Equipment, Appliance, and 

Component Manufacturing

335 36

Transportation Equipment Manufacturing 336 37

Miscellaneous Manufacturing 339900 39

Scrap and Waste Materials 423930 5093

Materials Recovery Facilities 562920 4953

SLAB Revisions

The SLAB revisions in this final rule affect all persons who export SLABs for 

reclamation in any foreign country. Potentially affected entities may include, but are not 

limited to:

Industry Sector NAICS SIC

Hazardous Waste Collectors 562112 4212

Recyclable Material Hauling, Long-Distance 484230 4213

Batteries, automotive, merchant wholesalers 423120 5013

Lead-acid storage batteries, manufacturing 335911 3691

Automotive Parts, Accessories, and Tire Stores 441310 5013

Tire Dealers 441320 5014

All other General Merchandise Stores 452990 5399

New Car Dealers 441110 5511

Recyclable Material Wholesaler 423930 5093

Other Waste Collection 562119 4212

Recyclable Material Collection Services, Solid 

Waste Collection

562111 4212

Marinas 713930 4493

General Freight Trucking, Long-Distance, TL 484121 4213

General Freight Trucking, Long-Distance, LTL 484122 4213

Specialized Freight Trucking 484200 4213

Freight Carriers (except air couriers), Air 

Scheduled

481112 4512

Freight Charter Services, Air 481212 4522

Freight Railways, Line-Haul 482111 4011

Freight Transportation, Deep Sea, to and from 

Domestic Ports

483113 4424

Freight Transportation, Deep Sea, to or from 

Foreign Ports

483111 4412
13

Exception Report Revisions for Exports under subparts E and H of 40 CFR part 262

The exception report change to 40 CFR part 262, subpart E and subpart H of this 

final rule affect all persons who export hazardous waste, universal waste, or SLABs to 

any foreign country. Potentially affected entities may include, but are not limited to:

Industry Sector NAICS SIC

Utilities 221100 4939

Petroleum and Coal Products Manufacturing 324 29

Chemical Manufacturing 325100 28

Primary Metal Manufacturing 331 33

Fabricated Metal Product Manufacturing 332 34

Machinery Manufacturing 333 35

Computer and Electronic Product Manufacturing 334110 357

Electrical Equipment, Appliance, and 

Component Manufacturing

335 36

Transportation Equipment Manufacturing 336 37

Miscellaneous Manufacturing 339 39

Scrap and Waste Materials 423930 5093

Import Consent Documentation

The import revisions in this final rule affect all facilities receiving imported 

hazardous waste from a foreign country that must comply with either §264.71(a)(3) or 

§265.71(a)(3). This includes those hazardous waste import shipments originating in 

OECD countries, as well as in non-OECD countries. Potentially affected entities may

include, but are not limited to:

 

Industry Sector NAICS SIC

Hazardous Waste Collectors 562112 4212

Recyclable Material Wholesaler 423930 5093

Other Waste Collection 562119 4212

Recyclable Material Collection Services, Solid 

Waste Collection

562111 4212

Scrap and Waste Materials 423930 5093

Materials Recovery Facilities 562920 4953

The lists of potentially affected entities in the above tables may not be exhaustive. 

The Agency’s aim is to provide a guide for readers regarding those entities that 

potentially could be affected by this action. However, this action may affect other 

entities not listed in these tables. 
14

4(b) Information Requested

OECD Revisions

Under the final §262.82(g), the transboundary movement of an Amber waste is 

exempt from the Amber control procedures if it is in certain quantities and destined for 

laboratory analysis to assess its physical or chemical characteristics, or to determine its 

suitability for recovery operations. The quantity of such waste shall be determined by the 

minimum quantity reasonably needed to perform the analysis in each particular case 

adequately, but in no case exceed twenty-five kilograms (25 kg). As a result, the affected 

entities will experience cost savings, since they will no longer need to comply with the 

information collection requirements under the existing regulations. 

(i) Data Item:

• None

(ii) Respondent Activities:

• None

Under the final §262.83(e), recovery facilities must provide a certificate of 

recovery to the exporter and to the competent authorities of the countries of export and 

import. This certificate of recovery must be provided as soon as possible, but no later 

than 30 days after the completion of recovery and no later than one calendar year 

following receipt of waste. 

(i) Data Item:

• A certificate of recovery by mail, e-mail without a digital signature 

followed by mail, or fax followed by mail.

(ii) Respondent Activities:

• Prepare and maintain a copy of the certificate of recovery for each 

hazardous waste shipment.

Under the final §262.82(f), the transboundary movement of wastes destined for 

R12 (exchange) and R13 (accumulation) operations must comply with all Amber control 

procedures for notification and consent as set forth in §262.83 and for the movement 

document as set forth in §262.84. Additional responsibilities of R12/R13 facilities 

include:

If wastes are destined for an R12/R13 recovery facility, exporters also must 

indicate in the notification the name, address, and telephone and telefax number 
15

of the recovery facility or facilities where the subsequent R1-R115recovery

operation takes place or may take place.

Within three days of the receipt of the wastes by the R12/R13 recovery facility, 

the facility must return a signed copy of the movement/tracking document to the 

exporter and to the competent authorities of the countries of export and import. 

The facility must retain the original of the movement/tracking document for three 

years.

As soon as possible, but no later than 30 days after the completion of the R12/R13 

recovery operation and no later than one calendar year following the receipt of the 

waste, the R12/R13 recovery facility must send a certificate of recovery to the 

exporter and to the competent authorities of the countries of export and import.

When an R12/R13 recovery facility delivers wastes for recovery to an R1-R11 

recovery facility located in the country of import, it must obtain as soon as 

possible, but no later than one calendar year following delivery of the waste, a 

certification from the R1-R11 facility that recovery of the wastes at that facility

has been completed. The R12/R13 facility must promptly transmit the applicable 

certification to the competent authorities of the countries of import and export, 

identifying the transboundary shipments to which the certification pertain. 

When an R12/R13 recovery facility delivers wastes for recovery to an R1-R11 

recovery facility located in the initial country of export or in a third country other 

than the initial country of export, a new notification is required.

(i) Data Item:

• Notification from the exporters indicating the foreseen recovery facility or 

facilities where the subsequent R1-R11 recovery operation takes place or 

may take place

• A signed copy of the movement/tracking document from the R12/R13 

recovery facility to the exporter and to the competent authorities of the

countries of export and import

• A certificate of recovery from the R12/R13 recovery facility to the 

exporter and to the competent authorities of the countries of export and 

import

 

5 Recovery operations R1 through R11 are defined in §262.81 as the following: R1, use as a fuel (other 

than in direct incineration) or other means to generate energy; R2, solvent reclamation/regeneration; R3, 

recycling/reclamation of organic substances which are not used as solvents; R4, recycling/reclamation of 

metals and metal compounds; R5, recycling/reclamation of other inorganic materials; R6, regeneration of 

acids or bases; R7, recovery of components used for pollution abatement; R8, recovery of components used 

from catalysts; R9, used oil re-refining or other reuses of previously used oil; R10, land treatment resulting 

in benefit to agriculture or ecological improvement; and, R11, uses of residual materials obtained from any

of the operations numbered R1-R10.
16

• A certificate of recovery from the R1-R11 facility located in the country of 

import to the R12/R13 recovery facility

• A new notification when an R12/R13 recovery facility delivers wastes for 

recovery to an R1-R11 recovery facility located in the initial country of 

export or in a third country other than the initial country of export

(ii) Respondent Activities:

• Exporters must indicate in the notification the recovery facility where the 

subsequent R1-R11 recovery operation takes place or may take place.

• The R12/R13 recovery facility must return a signed copy of the 

movement/tracking document to the exporter and to the competent 

authorities of the countries of export and import. The facility must retain 

the original of the movement/tracking document for three years.

• After the completion of the R12/R13 recovery operation, the R12/R13 

recovery facility must send a certificate of recovery to the exporter and to 

the competent authorities of the countries of export and import.

• When an R12/R13 recovery facility delivers wastes for recovery to an 

R1-R11 recovery facility located in the country of import, it must obtain a 

certificate of recovery from the R1-R11 facility. The R12/R13 facility

must promptly transmit the certificate to the competent authorities of the 

countries of import and export. 

• When an R12/R13 recovery facility delivers wastes for recovery to an 

R1-R11 recovery facility located in the initial country of export or in a 

third country other than the initial country of export, a new notification is 

required.

Under the final §262.82(c), §262.82(d), and §262.82(e), when a transboundary

movement of wastes to which concerned OECD Countries have given consent cannot be 

completed as intended (e.g., not in accordance with the notification, consents given by

the competent authorities, or the terms of the contract) and alternative arrangements 

cannot be made to recover these wastes in an environmentally sound manner in the U.S.,

the hazardous waste must be returned to the country of export or re-exported to a third 

country. The return of the hazardous waste to the country of export is to take place 

within ninety (90) days from the time when the country of export was informed of the 

incident, or such other period of time to which all concerned countries agree. 

(i) Data Item:

• Notification to inform EPA of need to return shipment. 
17

(iii) Respondent Activities:

• U.S. importer must prepare and submit notification to EPA of the need to 

return the shipment to the country of export.

SLAB Revisions

EPA is amending the RCRA regulations for SLABs specified in 40 CFR part 266 

subpart G by requiring notification and consent for the export of SLABs. The final action 

prescribes specific export requirements for SLAB exports to two groups of countries, i.e., 

OECD countries (except for Canada and Mexico), and non-OECD countries (including 

Canada and Mexico). Specifically, the SLAB exports going to OECD countries will fall 

under the revised 40 CFR part 262 subpart H, while those going to non-OECD countries 

will be governed under 40 CFR part 262 subpart E, consistent with Universal Waste 

requirements. While subparts E and H are different regulations, the requirements for 

SLAB exports are largely similar. 

Under §262.53(a) & (b) and §262.83(b) & (e), exporters must notify EPA of their 

intent to export SLABs and seek an Acknowledgement of Consent. The notification must 

contain detailed information with regard to the identity of the exporter, waste type, means 

of transport, ultimate destination facility, methods of treatment, recovery, and disposal, 

and destination and transit countries. 

§262.53(a) & (b) - for SLAB Exports to Non-OECD Countries, Canada and 

Mexico

(i) Data Item:

• Written notification. The notification must contain detailed information 

regarding the exporter, waste details, transporters, means of transport and 

containers to be used, all points of entry and departure for each foreign 

country of transit, receiving facility information, and ultimate management 

method. 

(ii) Respondent Activities:

• Prepare and submit written notification at least 60 days before the initial 

shipment is intended to be shipped off site. This notice may cover export 

activities extending over a 12 month period. 

§262.83(b) & (e) - for SLAB Exports to OECD Countries Other Than Canada and 

Mexico

(i) Data Item:
18

• Written notification including a signed certification/declaration by the 

exporter with required wording. The notification must include detailed 

information regarding the shipment such as exporter details; recovery

facility name and method of recovery; names and details of all 

transporters; details of all countries of import, transit, and import; and 

waste information including waste description meeting OECD 

requirements. 

(ii) Respondent Activities:

• Prepare and submit written notification at least 45 days prior to shipment. 

This notice may cover export activities over a 12 month period. 

Under §262.53(c) and §262.83(b), when the conditions specified on the original 

notification change, the primary exporter must provide EPA with a renotification of the 

change. Also, where a shipment cannot be delivered for any reason, the exporter must 

renotify EPA of a change in the conditions and obtain a new EPA Acknowledgement of 

Consent.

§262.53(c) - for SLAB Exports to Non-OECD Countries, Canada and Mexico

(i) Data Item:

• Written renotification if the conditions specified on the original 

notification change.

(ii) Respondent Activities:

• Provide a renotification of the export change after the original notification.

§262.83(b) - for SLAB to OECD Countries Other Than Canada and Mexico

(i) Data Item:

• Renotification required after the previous consent has expired.

(ii) Respondent Activities:

• Provide a renotification if the notification expires prior to shipment. 

Under §262.56 and §262.87(a), exporters must file detailed annual reports on 

SLAB exports containing information such as waste types, quantities, frequency, and 

ultimate destination of all exports, among others.

§262.56 - for SLAB Exports to Non-OECD Countries, Canada, and Mexico
19

(i) Data Item:

• Annual report including a signed certification by the exporter with 

required wording, summarizing the types, quantities, frequency, and 

ultimate destination of all hazardous waste exported during the previous 

calendar year.

(ii) Respondent Activities:

• Prepare and submit the required annual report.

§262.87(a) - for SLAB Exports to OECD Countries Other Than Canada and 

Mexico

(i) Data Item:

• Annual report including a signed certification by the exporter with 

required wording, summarizing the types, quantities, frequency, and 

ultimate destination of all hazardous waste exported during the previous 

calendar year. During even numbered years, LQGs must include a 

description of waste reduction efforts and changes in waste generation 

(except for waste reported in the generators Biennial Report submission) 

in the annual report.

(ii) Respondent Activities:

• Prepare and submit the required annual report no later than March 1 of

each year. 

Under §262.53(d), §262.83(d)(14), §262.85(e), and §262.85(g), an exporter shall 

furnish to EPA any additional information which a receiving country requests in order to 

respond to a notification upon request by EPA.

§262.53(d) - for SLAB Exports to Non-OECD Countries, Canada and Mexico

(i) Data Item:

• Additional information which a receiving country requests in order to 

respond to a notification.

(ii) Respondent Activities:

• Collect and submit additional information requested by EPA.

§262.83(d)(14), §262.85(e), and §262.85(g) - for SLAB Exports to OECD 

Countries Other Than Canada and Mexico
20

(i) Data Item:

• Additional information regarding financial assurances or contractual 

arrangements which a receiving country requests in order to respond to a 

notification (as discussed in existing notes to §262.83(d)(14) and 

§262.85(e), and in the existing §262.85(g)).

(ii) Respondent Activities:

• Collect and submit additional information requested by EPA.

Under §262.52(c) and §266.80(a) Item 6 in the table, an exporter must provide a 

copy of the EPA Acknowledgement of Consent for the shipment to the transporter 

transporting the shipment for the export of SLABs to a non-OECD country, Canada, or 

Mexico.

(i) Data Item:

• Acknowledgment of Consent for the shipment to the transporter

(ii) Respondent Activities:

• Provide a copy of the EPA Acknowledgement of Consent for the shipment 

to the transporter.

Under the recordkeeping requirements in §262.57 and §262.87(c), the exporter 

must keep a copy of each notification, the EPA Acknowledgment of Consent, each 

confirmation of delivery and each annual report, all for a period of at least 3 years. 

§262.57 - for SLAB Exports to Non-OECD Countries, Canada and Mexico

(i) Data Item:

• Notifications

• EPA Acknowledgement of Consent

• Confirmation of delivery

• Annual reports

(ii) Respondent Activities:

• Maintain the required records for at least three years.
21

§262.87(c) - for SLAB Exports to OECD Countries Other Than Canada and 

Mexico

(i) Data Item:

• Notifications

• Written consents 

• Confirmation of delivery 

• Exception reports 

• Confirmation of recovery 

• Annual reports

(ii) Respondent Activities:

• Maintain the required records for at least three years.

Under the shipment tracking requirements in §262.84 for slab exports to OECD 

countries other than Canada and Mexico, all U.S. parties subject to the contract 

provisions under §262.85 must accompany a movement document with the waste until it 

reaches the final recovery facility. This movement document must include all the 

information required under §262.83 (for notification) and additional information 

regarding the shipment of the waste such as transport requirements and transporter 

information. 

(i) Data Item:

• A movement document accompanying all shipments for export. The 

movement document must include all the information required for 

notification and additional information regarding the shipment 

requirements. The document must also include a signed 

certification/declaration by the exporter with required wording.

(ii) Respondent Activities:

• Prepare the movement document and provide it with each shipment. 

Under §262.87(b) for SLAB exports to OECD countries other than Canada and 

Mexico, an exporter must file an exception report if any of the following occurs: (1) it 

has not received a copy of the movement documentation signed by a transporter stating 

point of departure from the U.S., within 45 days of acceptance of waste, (2) within 90 

days from the acceptance of waste, the exporter has not received written confirmation 
22

from the recovery facility that the waste was received, or (3) the waste is returned to the 

U.S. 

(i) Data Item:

• Exception report if any of the situations specified in §262.87(b) occurs.

(ii) Respondent Activities:

• Prepare and submit the required exception report if any of the conditions 

listed in §262.87(b) occurs.

Under §262.83(e) for SLAB exports to OECD countries other than Canada and 

Mexico, recovery facilities must provide a certificate of recovery to the exporter and to 

the competent authorities of the countries of export and import. This certificate of 

recovery must be provided as soon as possible, but no later than 30 days after the 

completion of recovery and no later than one calendar year following receipt of waste. 

(i) Data Item:

• A certificate of recovery

(ii) Respondent Activities:

• Provide a certificate of recovery to the exporter and to the competent 

authorities of the countries of export and import.

Import Consent Documentation

Under the amended import requirements in §264.71(a)(3) and §265.71(a)(3), the 

U.S. receiving facility must match the relevant documentation confirming EPA’s consent 

to import to an incoming import shipment’s RCRA hazardous waste manifest, and submit 

a copy of the matched consent documentation along with the shipment’s RCRA 

hazardous waste manifest (currently required to be submitted) to EPA within 30 days of 

import shipment delivery. 

(i) Data Item:

• Documentation confirming EPA’s consent to the import of hazardous 

waste

(ii) Respondent Activities:

• Submit to EPA the written documentation of EPA’s consent to import 

within thirty (30) days of shipment delivery.
23

5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, 

COLLECTION METHODOLOGY, AND INFORMATION 

MANAGEMENT

5(a) Agency Activities

OECD Revisions

Under §262.82(g), the transboundary movement of an Amber waste is exempt 

from the Amber control procedures if it is in certain quantities and destined for laboratory

analysis to assess its physical or chemical characteristics, or to determine its suitability

for recovery operations. As a result, the affected entities and EPA will incur cost savings.

Under §262.82(c), §262.82(d), and §262.82(e), when a transboundary movement 

of wastes to which concerned OECD Countries have given consent cannot be completed 

as intended (e.g., not in accordance with the notification, consents given by the 

competent authorities, or the terms of the contract) and alternative arrangements cannot 

be made to recover these wastes in an environmentally sound manner in the U.S., EPA 

must inform the competent authorities of the countries of export and transit, mentioning 

in particular the reason for returning the waste. 

There are no Agency activities associated with the other new/amended

requirements under the final OECD revisions. 

SLAB Revisions

Under §262.53(a) & (b) and §262.83(b) & (e), exporters must notify EPA of their 

intent to export SLABs and seek an Acknowledgement of Consent. EPA will process 

the notifications, forward them to the countries of import, receive and process consent 

from countries of import, and forward the Acknowledgement of Consent to the exporter. 

Under §262.53(c) and §262.83(b), when the conditions specified on the original 

notification change, the primary exporter must provide EPA with a renotification of the 

change. EPA will process these changes.

Under §262.56 and §262.87(a), exporters must file detailed annual reports on 

SLAB exports containing information such as waste types, quantities, frequency, and 

ultimate destination of all exports, among others. EPA will record the annual report 

information. 

Under §262.53(d), §262.83(d)(14), §262.85(e), and §262.85(g), an exporter shall 

furnish to EPA any additional information which a receiving country requests in order to 

respond to a notification upon request by EPA. EPA will request the information and 

process the information provided by exporters. 
24

Under §262.52(c) and §266.80(a) Item 6 in the table, an exporter of SLABs to 

non-OECD Countries, Canada and Mexico must provide a copy of the EPA 

Acknowledgement of Consent for the shipment to the transporter transporting the 

shipment for export to a non-OECD country, Canada, or Mexico. There are no Agency

activities associated with this requirement. 

Under §262.87(b), an exporter of SLABs to OECD Countries other than Canada 

and Mexico must file an exception report under certain conditions. There are no Agency

activities associated with this requirement. 

Under the recordkeeping requirements in §262.57 and §262.87(c), the exporter 

must keep a copy of each notification, EPA Acknowledgment of Consent, each 

confirmation of delivery and each annual report, all for a period of at least 3 years. There 

are no Agency activities associated with this requirement. 

Under the shipment tracking requirements in §262.84 for SLAB exports to OECD 

Countries other than Canada and Mexico, all U.S. parties subject to the contract 

provisions under §262.85 must accompany a movement document with the waste until it 

reaches the final recovery facility. There are no Agency activities associated with this 

requirement. 

Under §262.83(e) for SLAB exports to OECD Countries other than Canada and 

Mexico, recovery facilities must provide a certificate of recovery to the exporter and to 

the competent authorities of the countries of export and import. EPA will maintain the 

certificate of recovery from the recovery facility.

Import Consent Documentation

Under the amended import requirements in §264.71(a)(3) and §265.71(a)(3), the 

U.S. receiving facility must submit the documentation confirming EPA’s consent to 

import (along with a copy of the RCRA hazardous waste manifest currently required) to 

EPA within 30 days of import shipment. EPA will maintain the documentation from the 

U.S. receiving facility.

5(b) Collection Methodology and Management

The collection and management of the information submitted to EPA is stored by

EPA in file cabinets and/or electronically to be compiled in an annual status report. In 

addition, the information is collected and stored for possible future use in enforcement 

actions. EPA uses electronic equipment such as personal computers and applicable 

database software, when appropriate. 

5(c) Small Entity Flexibility

In promulgating the rule codifying the OECD Decision, EPA evaluated the impact 

on regulated small entities. The decision to export or import hazardous waste is voluntary.
25

Thus, no business, small or otherwise, is required to export or import its hazardous waste. 

Therefore, there is no mandatory burden on the regulated community, including small 

businesses. Furthermore, for small businesses that do choose to export or import 

hazardous waste, EPA exempted conditionally exempt small quantity generators (less 

than 100 kilograms per month) from the requirements of the rule.

5(d) Collection Schedule

Under the final revisions to the OECD rule and SLAB regulations, export 

notifications, exception reports, documentation of EPA’s consent to import, certificates 

of recovery, and shipment tracking documents are generated and sent to EPA on an

occurrence-specific basis for which there is no formalized schedule. 

Documentation of EPA’s consent to import must be submitted by the U.S. 

receiving facility to EPA (along with the RCRA hazardous waste manifest currently 

required) within 30 days of import shipment delivery.

Recovery facilities must provide a certificate of recovery to the exporter and to 

the competent authorities of the countries of export and import. This certificate of 

recovery must be provided as soon as possible, but no later than 30 days after the 

completion of recovery and no later than one calendar year following receipt of waste.

For SLAB exports to Non-OECD countries, Canada and Mexico, export

notifications must be sent to EPA at least 60 days before the initial shipment is intended 

to be shipped off site. For SLAB exports to OECD countries Other than Canada and 

Mexico, export notifications must be sent to EPA within 45 days prior to initiating waste 

exports (or at least ten days if the shipment is going to a pre-approved facility in the 

country of import).

Exporters must file with EPA a detailed annual report on SLAB exports,

including a signed certification, by March 1st of each year.

6. ESTIMATING THE HOUR AND COST BURDEN OF THE 

COLLECTION

6(a) Estimating Respondent Burden

OECD Revisions

EPA assessed the potential cost impacts of the final revisions to the OECD rule, 

including: 

 Exemptions for wastes destined for laboratory analyses,

 The requirement to provide a certificate of recovery,
26

 Information collection requirements associated with exchange (R12) and 

accumulation (R13) recovery operations, and

 The notification requirements related to the return of wastes.

SLAB Revisions

EPA assessed the potential cost impacts of the final revisions to the SLAB 

regulations, including: 

 Notification requirements for SLAB exporters,

 The renotification requirements associated with any changes to the original SLAB 

export notification, 

 The annual reporting requirements,

 Additional reporting requirements (if requested by EPA), and

 SLAB exporter recordkeeping requirements. 

Import Consent Documentation

EPA analyzed the final requirement that the U.S. receiving facility must match the 

RCRA manifest to the relevant import notice consent documentation, and must send a 

copy of the matched RCRA manifest (currently required to be submitted) and import 

consent documentation back to EPA within thirty days of delivery.

Exception report revisions for exports under subparts E and H of 40 CFR part 262

The final revision to the current language in §262.55 and §262.87(b) will require 

exception reports to be submitted directly to the Director, ICAD, of OECA, EPA 

Headquarters, rather than to the EPA “Administrator.” There is no discernable cost 

impact associated with this final requirement. 

6(b) Estimating Respondent Costs

Labor Costs

For U.S. exporters, U.S. importers, and U.S. transporters, EPA estimates an 

average hourly labor rate (including fringe and overhead) of $98.86 for managerial staff, 

$64.71 for technical staff, and $33.85 for clerical staff.6 These labor rates were obtained 

from the Cost Assessment in Support of the Proposed Rule on Exports and Imports of 

Hazardous Waste Destined for Recovery among OECD Countries7and updated to 2007 

 

6

 See section 3.1 of the “Cost Assessment for the Final Rule on Exports and Imports of Hazardous Waste 

Destined for Recovery Among OECD Countries, Exports of Spent Lead-Acid Batteries from the U.S., and 

Import Consent Documentation” (hereinafter referred to as the Cost Assessment document for the final

rule), which is available in the docket for the rule.

7 U.S. EPA. September 27, 2004 (revised February 24, 2005). Cost Assessment in Support of the Proposed 

Rule on Exports and Imports of Hazardous Waste Destined for Recovery among OECD Countries
27

levels using Employment Cost Indices developed by the U.S. Bureau of Labor Statistics.8

Annual Capital and Operation & Maintenance (O&M) Costs

Capital costs usually include any produced physical good needed to provide the 

needed information, such as machinery, computers, and other equipment. O&M costs are 

those costs associated with paperwork requirements incurred continually over the life of 

the ICR. They are defined by the EPA as “the recurring dollar amount of costs associated 

with O&M or purchasing services.” Such capital and O&M costs are expected to be 

negligible.

 The materials costs used in this analysis are described in the following 9and 

summarized in Table 1:

 Mailing costs10: EPA estimates that affected entities will incur a cost of $4.24 

to mail a five-ounce package by certified mail ($1.48 for postage, $2.65 for 

the certified-mail fee, and $0.11 for a 9 x 12 manila envelope). 

Affected entities are estimated to incur a cost of $0.42 for each standard 

letter mailed ($0.41 for first class postage and $0.01 for a standard 

envelope). 

 Copying Costs: EPA estimates that affected entities will incur a cost of $0.11 

per page for copying. 

 Faxing costs: EPA estimates that affected entities will incur a cost of $0.12 for 

each international fax they send. This cost was derived from the average 

revenues per minute for a telephone call from the U.S. to an OECD Country 

(excluding Canada and Mexico). Revenue figures were obtained from the 

2005 International Telecommunications Data Report issued by the Federal 

Communications Commission on April 24, 2007. The cost estimate assumes 

that the fax transmission will take one-minute. 

 Domestic telephone call costs: EPA estimates that affected entities will incur 

a cost of $0.90 for each domestic telephone call they make. This cost was 

 

8 To update the hourly rates from 2004 to 2007 levels, EPA referred to Table 9. Employment Cost Index for 

Wages and Salaries, for Private Industry Workers by Occupation Group and Industry (Not seasonally 

adjusted) of Employment Cost Index: Historical Listing (December 2005 = 100), U.S. Bureau of Labor 

Statistics (July 31, 2007). This table presents employment cost indices for private industry workers, by 

annual quarter (i.e., for March, June, September, and December). EPA used the June 2004 Index (96.5) 

and the June 2007 Index (105.1) to develop an adjustment factor of 1.089 (i.e., 105.1 / 96.5 = 1.089). 

Available at: http://www.bls.gov/ncs/ect/home.htm.

9

See section 3.2 of the Cost Assessment document for the final rule.

10

 Based on the postal mail rates as of April 2008. U.S. First Class postage has since increased form $0.41 

to $0.42 per standard letter. This change is expected to have a negligible impact on total costs.
28

derived by averaging the advertised rates of a 15-minute State-to-State 

telephone call from four large U.S. long distance carriers. 

Table 1

Materials Costs Used to Assess the Cost Impacts of the Final Rule

Materials Cost Category Unit Cost

(2007 dollars)

Mailing Costs (9 x 12 package) $4.24

Mailing Costs (standard letter) $0.42

Copying Costs $0.11

Faxing Costs $0.12

Domestic Telephone Call Costs $0.90

6(c) Estimating Agency Burden and Costs

For Agency burden and costs, EPA estimates an average hourly labor rate of 

$60.66 for managerial staff (GS-14, Step 1), $51.33 for technical staff (GS-13, Step 1), 

and $29.76 for clerical staff (GS-9, Step 1).11 To derive these hourly estimates, EPA 

referred to the General Schedule (GS) Salary Table 2007. This publication summarizes 

the unloaded (base) hourly rate for various labor categories in the Federal government. 

EPA applied the standard government overhead factor of 1.6 to the unloaded rate to 

derive loaded hourly labor rates. 

6(d) Estimating the Respondent Universe and Total Burden and Costs

In this section, EPA first describes the respondent universe affected by the new

information collection requirements resulting from the final action. EPA then estimates 

the annual aggregate burden to respondents under the final rule and existing RCRA 

information collection requirements. The universe estimates and assumptions used in the 

development of this ICR are based on the economic assessment developed for this 

rulemaking: “Cost Assessment for the Final Rule on Exports and Imports of Hazardous 

Waste Destined for Recovery Among OECD Countries, Exports of Spent Lead-Acid 

Batteries from the U.S., and Import Consent Documentation” (hereinafter referred to as 

the Cost Assessment document for the final rule), which is available in the docket for the 

rule.

(1) Respondent Universe

OECD Revisions

 

11 See section 3.1 of the Cost Assessment document for the final rule.
29

In Table 2 below, EPA provides estimates of the annual number of importer and 

import shipments, and annual exporter and export shipments that will be subject to the 

paperwork requirements in the final rule.12

Table 2

Number of Import and Export Shipments potentially Affected by the Final

Revisions to EPA’s OECD Rule

Type of 

Shipment

Number of Affected Entities* Number of Shipments per Year

U.S. Exporters/ 

U.S. Importers

U.S. 

Transporters

Wastes Destined 

for Laboratory 

Analysis**

Wastes Destined 

for Recovery 

Operations***

Total

Export 6 6 10 479 489**

Import 15 15 4 296 300****

* EPA has assumed that there is one U.S. transporter for each U.S. exporter and U.S. importer.

** Of the 489 shipments to OECD Countries, 2.1 percent (10) are samples destined for laboratory 

analysis. The remaining 479 (i.e., 489 - 10) shipments are shipments of hazardous wastes destined 

for recovery.

*** Of the 479 export shipments of hazardous wastes destined for recovery, it is estimated that 12 

percent (or 57 shipments) are shipped to R12/R13 recovery facilities in OECD Countries.

Of the 296 import shipments of hazardous wastes destined for recovery, 36 shipments (or 12 

percent) are received at R12/R13 recovery facilities in the U.S.

**** Of the 300 shipments from OECD Countries, 1.4 percent (4) are samples destined for laboratory 

analysis. The remaining 296 (i.e., 300 - 4) shipments are shipments of hazardous wastes destined 

for recovery.

SLAB Revisions

In Table 3 below, EPA provides estimates of the annual number of export 

shipments that will be subject to the paperwork requirements in the final rule.13

Table 3

Number of Export Shipments potentially Affected by the Final SLAB Revisions

Type of 

Shipment

Number of Affected Entities* Number of SLAB Export 

Shipments Per Year

Number of Notices 

Per Year

U.S. SLAB 

Exporters

U.S. SLAB 

Transporters

Export 1,141** 571 16,154 668

* Assumes 1,141 exporters, zero importers, and 571 transporters. See universe assumptions 

discussed in Sections 3.4, 4.2 and 4.7 of the Cost Assessment document for the final rule.

** EPA estimates that 640 U.S. exporters of SLABs will be required to prepare and submit an annual 

 

12 These assumptions are discussed in detail in section 3.3.2 of the Cost Assessment document for the final

rule.

13 These assumptions are discussed in detail in section 3.4.2 of the Cost Assessment document for the final

rule.
30

report under the final rule. 27 of these exporters are assumed to be small exporters and the 

remaining 613 are assumed to be large exporters. 

Import Consent Documentation

In Table 4 below, EPA provides estimates of the annual number of importer and 

import shipments, and annual exporter and export shipments that will be subject to the 

paperwork requirements in the final rule.14

Table 4

Number of Import Shipments potentially Affected by the Final Import Consent 

Documentation Requirements

Type of 

Shipment

Number of 

Affected U.S. 

Receivers*

Number of Import Shipments

Per Year*

Import 136 2,712

* The ratio of shipments to receivers is estimated to be 20 to 1.

(2) Annual Respondent Hour and Cost Burden under the Final Rule

OECD Revisions

(a) Reading the Regulations

Affected entities are expected to incur first year incremental costs associated with 

reading the rule in order to understand and comply with the new requirements. EPA 

estimates that a total of 42 entities (i.e., six U.S. exporters, 15 U.S. importers, and 21 U.S. 

transporters) will read the final rule in order to understand and comply with the new 

requirements. EPA also estimates that each entity will experience a cost of $114.14 in 

reading the rule.15 Thus, collectively, U.S. exporters, U.S. importers, and U.S. 

transporters may experience a one-time cost of approximately $4,794 (i.e., 42 entities x 

$114.14/entity) for this activity. See Exhibit 1.

(b) Exemption for Wastes Destined for Laboratory Analysis

Under §262.82(g), shipments of Amber-list wastes are exempt from the Amber 

control procedure if they are explicitly destined for laboratory analysis to assess their 

physical/chemical characteristics or to determine their suitability for recovery operations. 

As a result, the affected entities will experience cost savings, since they will no longer 

 

14 These assumptions are discussed in detail in Section 3.5.2 of the Cost Assessment document for the final

rule.

15 See section 4.1.1 of the Cost Assessment document for the final rule.
31

need to comply with the information collection requirements under the existing 

regulations. 

EPA provides the estimated cost savings associated with the exemption for wastes 

destined for laboratory analysis in Exhibit 2 (for exports from the U.S. to OECD 

Countries) and Exhibit 3 (for imports to the U.S. from OECD Countries). For detailed 

discussions, see Section 4.1.2 of the Cost Assessment document for the final rule.

(c) Certificate of Recovery

Under §262.83(e), recovery facilities must provide a certificate of recovery to the 

exporter and to the competent authorities of the countries of export and import. This 

certificate of recovery must be provided as soon as possible, but no later than 30 days 

after the completion of recovery and no later than one calendar year following receipt of 

waste. 

EPA presents the costs associated with the certificate of recovery in Exhibit 4. 

For detailed discussions, see Section 4.1.3 of the Cost Assessment document for the final

rule.

(d) Exchange and Accumulation Recovery Operations

Under §262.82(f), shipments of hazardous wastes destined for exchange (R12) or 

accumulation (R13) recovery operations need to comply with additional information 

collection requirements. These requirements include: (1) indicating the subsequent R1-

R11 recovery facility (e.g., facility that conducts solvent reclamation, acid regeneration) 

in the notification, (2) providing and maintaining a signed copy of the movement/tracking 

document, (3) preparing and providing a certificate of recovery for R12/R13 recovery

operations, and (4) providing and maintaining a copy of the certificate of recovery for 

R1-R11 recovery operations. 

EPA’s estimated costs associated with these requirements are presented in Exhibit 

5. For detailed discussions, see Section 4.1.4 of the Cost Assessment document for the 

final rule.

(e) Return of Wastes

Under §262.82(c), §262.82(d), and §262.82(e), when a shipment of hazardous 

wastes to which concerned countries have given consent cannot be completed in 

accordance with the terms of the contract and alternative arrangements cannot be made to 

recover these wastes in an environmentally sound manner in the U.S., EPA must inform 

the competent authorities of the countries of export and transit the reason for returning 

the waste. The U.S. importer must then complete the return within 90 days from the time 

EPA informs the country of export of the need to return the waste, unless informed in 

writing by EPA of another timeframe agreed to by the concerned Member countries. 
32

In Exhibit 6, EPA presents the estimated costs associated with the return of 

wastes. For detailed discussions, see Section 4.1.5 of the Cost Assessment document for 

the final rule.

SLAB Revisions

Since the SLAB Rule applies only to the export of SLABs, U.S. importers will 

not experience any costs or cost savings from the rule. 

(a) Reading the Regulations

EPA estimates that a total of 1,712 entities (i.e., 1,141 U.S. exporters and 571

U.S. transporters) will read the rule during the first year of implementation in order to 

understand and comply with the new requirements. We also estimate that each entity will 

experience a cost of $260.64 in reading the rule. Thus, collectively, U.S. exporters and 

U.S. transporters may experience a one-time cost of approximately $446,207 (i.e., 1,712

entities x $260.64/entity) for this activity. In Exhibit 7, EPA presents the estimated costs 

associated with reading the regulations. For detailed discussions, see Section 4.2.1 of the 

Cost Assessment document for the final rule.

For SLAB Exports to Non-OECD Countries, Canada and Mexico

The following analysis of cost impacts associated with the final 40 CFR part 262, 

subpart E requirements assumes that all SLABs are exported to Canada and Mexico 

based on the fact that the vast majority of SLABs are exported to these two countries 16

and are currently not subject to any export requirements. (The cost impacts of the final

40 CFR part 262, subpart H requirements that apply only to the export of SLABs to 

OECD countries (except Canada and Mexico), discussed separately below under For

SLAB Exports to OECD Countries Other Than Canada and Mexico, are not assessed 

given such export represents a very small percentage of the total SLAB export quantity.)

(b) Notification

Under §262.53(a) & (b) and §262.83(b) & (e), the exporters must submit a 

notification to EPA indicating their intent to export SLABs. EPA then must process the 

notification and seek consent from the countries of imports and transit. EPA will 

undertake the following tasks to complete the notification process and issue an 

Acknowledgment of Consent: 

 Receive and process the notification from the U.S. exporter

 Prepare and transmit a confirmation of receipt to the U.S. exporter

 Forward the notification to the competent authorities of the countries of import 

and transit. 

 Receive and process consent or objection from the competent authorities of the 

countries of import and transit. 

 

16 See discussion in Section 3.4 and Attachment E of the Cost Assessment document for the final rule. 
33

 Forward written Acknowledgement of Consent or objection to U.S. exporter. 

In Exhibit 8, EPA presents the estimated costs associated with the notification 

requirement. For detailed discussions, see Section 4.2.2 of the Cost Assessment 

document for the final rule.

(c) Renotification

Under §262.53(c) and §262.83(b), when the conditions specified under the 

original notification change, the U.S. exporter must provide EPA with a renotification of 

the change. Also, where a shipment cannot be delivered for any reason, the exporter

must renotify EPA of a change in the conditions and obtain a new EPA 

Acknowledgement of Consent. It is estimated that only a fraction of exporters will be 

subject to this requirement. In Exhibit 9, EPA presents the estimated costs associated 

with the renotification requirement. For detailed discussions, see Section 4.2.3 of the 

Cost Assessment document for the final rule.

(d) Annual Report

Under §262.56 and §262.87(a), exporters must submit detailed annual reports to 

EPA on SLAB exports containing information such as waste types, quantities, frequency, 

and ultimate destination of all exports, among others. In Exhibit 10, EPA presents the 

estimated costs associated with the annual report requirement. For detailed discussions, 

see Section 4.2.4 of the Cost Assessment document for the final rule.

(e) Additional Report

Under §262.53(d), §262.83(d)(14), §262.85(e), and §262.85(g), upon request by

EPA, an exporter must submit to EPA any additional information which a receiving 

country requests in order to respond to a notification. In Exhibit 11, EPA presents the 

estimated costs associated with the additional reporting requirement. For detailed 

discussions, see Section 4.2.5 of the Cost Assessment document for the final rule.

(f) Acknowledgment of Consent to Transporter 

Under §262.52(c) and §266.80(a) Item 6 in the table, the exporter is required to 

provide a copy of the EPA Acknowledgment of Consent for each shipment to the 

transporter transporting the shipment for export. EPA will not experience any costs 

associated with this requirement. In Exhibit 12, EPA presents the estimated costs 

associated with the Acknowledgment of Consent requirement. For detailed discussions, 

see Section 4.2.6 of the Cost Assessment document for the final rule.

(g) Recordkeeping

Under §262.57 and §262.87(c), U.S. exporters must keep a copy of each 

notification, EPA Acknowledgement of Consent, each confirmation of delivery, and each 
34

annual report for a period of at least 3 years. In Exhibit 13, EPA presents the estimated 

costs associated with the recordkeeping requirement. For detailed discussions, see 

Section 4.2.7 of the Cost Assessment document for the final rule.

For SLAB Exports to OECD Countries Other Than Canada and Mexico

Below are the requirements of 40 CFR part 262, subpart H associated only with 

the export of SLABs to OECD countries other than Canada and Mexico. That is, these 

requirements are not required of SLAB exports to non-OECD countries, Canada and 

Mexico.

17 The cost impacts associated with the export of SLABs to OECD counties 

other than Canada and Mexico are not assessed given it is a very small percentage of the 

total SLAB export quantity.

18 The costs estimated above for the export of SLABs to nonOECD countries, Canada and Mexico remain as the base costs. 

(h) Movement/Tracking Document 

Under §262.84, each time a U.S. exporter ships SLABs to an OECD Member 

country other than Canada and Mexico, the exporter is required to complete and submit 

to the carrier a movement/tracking document. No incremental costs are expected for 

transporters. As noted above, the cost impact of this requirement associated with the 

export of SLABs to OECD counties other than Canada and Mexico is not assessed given

it is a very small percentage of the total SLAB export quantity.

(i) Exception Report

Under §262.87(b), an exporter must file an exception report if they do not receive 

the necessary documentation required by the rule to confirm transfer of the waste and 

receipt by the recovery facility within the allotted period of time or if the waste is 

returned to the U.S. As noted above, the cost impact of this requirement associated with 

the export of SLABs to OECD counties other than Canada and Mexico is not assessed 

given it is a very small percentage of the total SLAB export quantity.

(j) Certificate of Recovery

Under §262.83(e), recovery facilities must provide a certificate of recovery to the 

exporter and to the competent authorities of the countries of export and import. This 

certificate of recovery must be provided as soon as possible, but no later than 30 days 

after the completion of recovery and no later than one calendar year following receipt of 

waste. As noted above, the cost impact of this requirement associated with the export of 

 

17

 On the other hand, the Acknowledgement of Consent to Transporter requirement is required only of 

SLAB exports to non-OECD countries, Canada and Mexico under §262.52(c) and §266.80(a) as 

aforementioned, but is not required of SLAB exports to OECD countries other than Canada and Mexico. 

18 The Agency assumes that all of the SLABs will be exported to Canada and Mexico but not to OECD 

countries. See discussion in Section 3.4 and Attachment E of the Cost Assessment document for the final 

rule.
35

SLABs to OECD counties other than Canada and Mexico is not assessed given it is a 

very small percentage of the total SLAB export quantity.

Import Consent Documentation

(a) Receiving Facility Submission to EPA

Under §264.71(a)(3) and §265.71(a)(3), U.S. receivers will be required to submit 

the import consent documentation with manifest submission to EPA. In Exhibit 14, EPA 

presents the estimated costs associated with this provision. For detailed discussions, see 

Section 4.3.1 of the Cost Assessment document for the final rule.

(3) Annual Respondent Hour and Cost Burden under Existing 

Information Collection Requirements

In addition to the new paperwork requirements in the final rule, EPA identified 

several existing information collection activities in the following ICRs that will be 

undertaken by the potentially impacted facilities: 

● ICR No. 0820.10, OMB Control No. 2050-0035, "Hazardous Waste 

Generator Standards"

- Exporter requirements

- Importer-Exporter Requirements OECD and Bilateral

● ICR No. 1571.08, OMB Control No. 2050-0120, "General Hazardous 

Waste Facility Standards" 

- Foreign shipment Import Report (264.12(a) and 265.12(a))

● ICR No. 0261.15, OMB Control No. 2050-0028, "Notification of 

Regulated Waste Activity" 

6(e) Bottom Line Burden Hours and Costs

(1) Respondent Tally

In Exhibit 15, EPA provides the estimated total annual respondent burden and 

costs under the aforementioned new information collection activities. It shows that the 

total annual respondent burden under the final rule, including the cost of reading the rule

during the first year of implementation, is estimated to be 14,854 hours and $832,405. 

After the first year of implementation, the total annual respondent burden (i.e., excluding 

reading the rule) is estimated to be 8,799 hours and $381,404. Therefore, the bottom line 

three-year respondent burden is estimated to be 32,451 hours and $1,595,214. 

In Exhibit 16, EPA tallies respondents’ total hour and cost burden for both new 

and existing paperwork requirements associated with the final rule in order to derive 

aggregate burden.

(2) Agency Tally
36

Estimated Agency burden and costs for the various information collection 

activities under the final rule, as delineated in Section 5(a) above, are also presented in 

Exhibits 1 to 14, where applicable. EPA provides the estimated total annual burden to 

the Agency under the final rule in Exhibit 17. It shows that the total annual Agency

burden under the final rule is estimated to be 2,106 hours and $78,768. The three-year 

total Agency burden is thus estimated to be 6,317 hours and $236,305.

6(f) Reasons for Change in Burden

As aforementioned, the new paperwork requirements under the final rule are 

necessary to bring EPA’s hazardous waste regulations into compliance with the binding 

Amended 2001 OECD Decision; to make more uniform notification and consent practice 

for the export shipment of SLABs in order to ensure that SLABs are sent to reclamation 

facilities in countries that can manage them in an environmentally sound manner; and to 

require documentation of EPA’s consent to the import shipment of hazardous wastes in 

order to facilitate oversight of hazardous waste imports to the U.S.

6(g) Burden Statement

The annual public reporting burden for this ICR is estimated to average 3.63

hours/year per respondent under the final OECD revisions, 5.42 hours/year per 

respondent under the final SLAB revisions, and 8.44 hours/year per respondent under the 

final import consent documentation. The annual public recordkeeping burden is 

estimated to average 10.20 hours/year per respondent under the final OECD revisions, 

and 0.14 hours/year per respondent under the final SLAB revisions.

Burden means the total time, effort, or financial resources expended by persons to 

generate, maintain, retain, or disclose or provide information to or for a Federal agency. 

This includes the time needed to review instructions; develop, acquire, install, and utilize 

technology and systems for the purposes of collecting, validating, and verifying

information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable 

instructions and requirements; train personnel to be able to respond to a collection of 

information; search data sources; complete and review the collection of information; and 

transmit or otherwise disclose the information. An agency may not conduct or sponsor, 

and a person is not required to respond to, a collection of information unless it displays a 

currently valid OMB control number. The OMB control numbers for EPA's regulations 

are listed in 40 CFR part 9 and 48 CFR chapter 15.
37

Exhibit 1

OECD Revisions - Reading the Rule

(In the first year of Rule Implementation Only)

Cost per Entity Cost of All Entities

Activity Managerial 

Staff 

Hours

Technical 

Staff 

Hours

Clerical 

Staff

Hours

Hours Labor 

Costa

O&M

Costb

Total Cost Number of 

EntitiesC

Total 

Hours

Total Cost 

Reading the Regulations

U.S. Exporters 0.5 1 0 1.5 $114.14 $0.00 $114.14 6 9 $684.84 

U.S. Importers 0.5 1 0 1.5 $114.14 $0.00 $114.14 15 22.50 $1,712.10 

U.S. Transporters 0.5 1 0 1.5 $114.14 $0.00 $114.14 21 31.50 $2,396.94 

Total 42 63.00 $4,793.88 

a

 Based on hourly rates discussed in Section 3.1 of the Cost Assessment document for the final rule.

b

 Based on materials costs discussed in Section 3.2 of the Cost Assessment document for the final rule.

c

 Based on universe assumptions discussed in Section 3.3 of the Cost Assessment document for the final rule.
38

Exhibit 2

OECD Revisions - Exemption for Wastes Destined for Laboratory Analysis

For Exports from the U.S. to OCED Countries

Activity

Cost per Shipment Cost for All Shipments

Managerial 

Staff 

Hours

Technical 

Staff 

Hours

Clerical 

Staff 

Hours

Total 

Hours

Labor 

Costa

O&M

Costb

Total

Cost

Number of 

Shipmentsc

Total

Hours

Total

Cost

Exports from the U.S. to OCED Countries

U.S. Exporters 

Prepare and Submit Notification 

to EPA 

0.1 1.8 1.5 3.4 $177.14 $4.24 $181.38 10 34 $1,813.79 

Complete and Sign 

Movement/Tracking Document 

0 0.25 0 0.25 $16.18 $0.00 $16.18 10 2.5 $161.78 

Receive and maintain copy of 

notification of intent to export, 

Acknowledgment of Receipt, 

written consent/objection, and 

signed movement/tracking 

document provided by the 

recovery facility 

0 0 0.25 0.25 $8.46 $0.00 $8.46 10 2.5 $84.63 

Subtotal 0.1 2.05 1.75 3.9 $201.78 $4.24 $206.02 10 39 $2,060.19 

U.S. Transporters 

Upon obtaining physical custody 

of the waste, sign the 

movement/tracking document 

0 0.01 0 0.01 $0.65 $0.00 $0.65 10 0.1 $6.47 

Maintain copy of signed 

movement/tracking document 

0 0 0.1 0.1 $3.39 $0.00 $3.39 10 1 $33.85 

Upon delivery of the waste, 

obtain signed copy of 

movement/tracking document 

from the OECD Country 

recovery facility 

0 0.01 0 0.01 $0.65 $0.00 $0.65 10 0.1 $6.47 

Subtotal 0 0.02 0.1 0.12 $4.68 $0.00 $4.68 10 1.2 $46.79 

EPA

Receive and process notification 

from U.S. exporter 

0 1 0 1 $51.33 $0.00 $51.33 10 10 $513.30 
39

Activity

Cost per Shipment Cost for All Shipments

Managerial 

Staff 

Hours

Technical 

Staff 

Hours

Clerical 

Staff 

Hours

Total 

Hours

Labor 

Costa

O&M

Costb

Total

Cost

Number of 

Shipmentsc

Total

Hours

Total

Cost

Prepare and transmit 

confirmation of receipt to U.S. 

exporter 

0 0 0.25 0.25 $7.44 $0.12 $7.56 10 2.5 $75.60 

Forward notification to the 

competent authorities of the 

countries of import and transit

0 0 0.16 0.16 $4.76 $0.24 $5.00 10 1.6 $50.02 

Receive and process 

Acknowledgement of Receipt 

from the competent authority of 

the country of import

0 0 0.25 0.25 $7.44 $0.00 $7.44 10 2.5 $74.40 

Receive and process 

consent/objection from the 

competent authorities of the 

countries of import and transit 

0 0 0.16 0.16 $4.76 $0.00 $4.76 10 1.6 $47.62 

Forward Acknowledgement of 

Receipt and written 

consent/objection to U.S. 

exporter 

0 0 0.25 0.25 $7.44 $0.12 $7.56 10 2.5 $75.60 

Receive and process signed copy 

of movement/tracking document 

provided by the OECD Country 

recovery facility 

0 0 0.25 0.25 $7.44 $0.00 $7.44 10 2.5 $74.40 

Subtotal 0 1 1.32 2.32 $90.61 $0.48 $91.09 10 23.2 $910.93 

Total 0.1 3.07 3.17 6.34 $297.07 $4.72 $301.79 10 63.4 $3,017.91 

a Based on hourly rates discussed in Section 3.1 of the Cost Assessment document for the final rule.

b Based on materials costs discussed in Section 3.2 of the Cost Assessment document.

c Based on shipment estimates discussed in Section 4.1.2 of the Cost Assessment document.
40

Exhibit 3

OECD Revisions - Exemption for Wastes Destined for Laboratory Analysis

For Imports to the U.S. from OECD Countries

Cost per Shipment Cost for All Shipments

Activity Managerial 

Staff 

Hours

Technical 

Staff 

Hours

Clerical 

Staff 

Hours

Total 

Hours

Labor 

Costa

O&M

Costb

Total 

Cost

Number of 

Shipmentsc

Total

Hours

Total 

Cost

Imports to the U.S. from OECD Countries

U.S. Importers

Receive and maintain copy of 

confirmation of receipt 

0 0 0.25 0.25 $8.46 $0.00 $8.46 4 1 $33.85 

Sign movement/tracking document 

and provide copy to OECD 

Country exporter, EPA and

competent authority of the country 

of export 

0.08 0 0.25 0.33 $16.37 $0.00 $16.37 4 1.32 $65.49 

Subtotal 0.08 0 0.5 0.58 $24.83 $0.00 $24.83 4 2.32 $99.34 

U.S. Transporters 

Upon obtaining physical custody of 

the waste, sign the 

movement/tracking document 

0 0.01 0 0.01 $0.65 $0.00 $0.65 4 0.04 $2.59 

Maintain copy of signed 

movement/tracking document 

0 0 0.1 0.1 $3.39 $0.00 $3.39 4 0.4 $13.54 

Upon delivery of the waste, obtain 

signed copy of movement/tracking 

document from the OECD Country 

recovery facility 

0 0.01 0 0.01 $0.65 $0.00 $0.65 4 0.04 $2.59 

Subtotal 0 0.02 0.1 0.12 $4.68 $0.00 $4.68 4 0.48 $18.72 

EPA

Receive and process notification 

from the competent authority of the 

country of export 

0 1 0 1 $51.33 $0.00 $51.33 4 4 $205.32 

Prepare and transmit 

Acknowledgment of Receipt to the 

competent authorities of the 

countries of export and transit

0 0 0.25 0.25 $7.44 $0.24 $7.68 4 1 $30.72 
41

Cost per Shipment Cost for All Shipments

Activity Managerial 

Staff 

Hours

Technical 

Staff 

Hours

Clerical 

Staff 

Hours

Total 

Hours

Labor 

Costa

O&M

Costb

Total 

Cost

Number of 

Shipmentsc

Total

Hours

Total 

Cost

Prepare and transmit confirmation 

of receipt to U.S. importer

0 0 0.25 0.25 $7.44 $0.12 $7.56 4 1 $30.24 

Review notification to determine if 

U.S. recovery facility is authorized 

to handle the waste

0.5 1.5 0 2 $107.33 $0.00 $107.33 4 8 $429.30 

Prepare and provide written 

consent/objection to the competent 

authorities of the countries of 

export and transit 

0 0 0.25 0.25 $7.44 $0.24 $7.68 4 1 $30.72 

Receive and process signed copy of 

movement/tracking document 

provided by the U.S. recovery 

facility

0 0 0.25 0.25 $7.44 $0.00 $7.44 4 1 $29.76 

Subtotal 0.5 2.5 1 4 $188.42 $0.60 $189.02 4 16 $756.06 

Total 0.58 2.52 1.6 4.7 $217.93 $0.60 $218.53 4 18.8 $874.11 

a

 Based on hourly rates discussed in Section 3.1 of the Cost Assessment document for the final rule.

b Based on materials costs discussed in Section 3.2 of the Cost Assessment document.

c

 Based on shipment estimates discussed in Section 4.1.2 of the Cost Assessment document.
42

Exhibit 4

OECD Revisions - Certificate of Recovery

Activity

Cost per Shipment Cost for All Shipments

Managerial 

Staff 

Hours

Technical 

Staff 

Hours

Clerical 

Staff 

Hours

Total 

Hours

Labor 

Costa

O&M

Costb

Total 

Cost

Number of 

Shipmentsc

Total 

Hours

Total Cost

Exports from the U.S. to OECD Countries

Exporters

Receive and maintain the 

certificate of recovery provided 

by the OECD Country recovery 

facility

0 0 0.1 0.1 $3.39 $0.00 $3.39 479 47.90 $1,621.42 

EPA

Receive and maintain the 

certificate of recovery provided 

by the OECD Country recovery 

facility 

0 0 0.1 0.1 $2.98 $0.00 $2.98 479 47.90 $1,425.50 

Total 0 0 0.2 0.2 $6.36 $0.00 $6.36 479 95.80 $3,046.92 

Imports to the U.S. from OECD Countries

Importers

Prepare and provide certificate 

of recovery to OECD Country 

exporter, EPA, and the 

competent authority of the 

country of export 

0 0.2 0.25 0.45 $21.40 $0.36 $21.76 296 133.20 $6,442.29 

Maintain copy of certificate of 

recovery 

0 0 0.1 0.1 $3.39 $0.00 $3.39 296 29.60 $1,001.96 

Subtotal 0 0.2 0.35 0.55 $24.79 $0.36 $25.15 296 162.80 $7,444.25 

EPA

Receive and Maintain the 

certificate of recovery provided 

by the U.S. recovery facility 

0 0 0.1 0.1 $2.98 $0.00 $2.98 296 29.60 $880.90 

Total 0 0.2 0.45 0.65 $27.77 $0.36 $28.13 296 192.40 $8,325.15 

a

 Based on hourly rates discussed in Section 3.1 of the Cost Assessment document for the final rule.

b

 Based on materials costs discussed in Section 3.2 of the Cost Assessment document for the final rule.

c

 Based on shipment estimates discussed in Section 4.1.3 of the Cost Assessment document for the final rule.
43

Exhibit 5

OECD Revisions - Exchange and Accumulation Recovery Operations

Activity

Cost per Shipment Cost for All Shipments

Managerial 

Staff 

Hours

Technical 

Staff 

Hours

Clerical 

Staff 

Hours

Total 

Hours

Labor 

Costa

O&M

Costb

Total 

Cost

Number of 

Shipmentsc

Total 

Hours

Total Cost

Exports from the U.S. to OECD Countries

Exporters

Indicate in the notification the 

recovery facility where 

subsequent R1-R11 recovery 

took place 

0 0.02 0 0.02 $1.29 $0.00 $1.29 57 1.14 $73.77 

EPA

Receive and maintain the 

certificate of recovery provided 

by the OECD Country R12/R13 

recovery facility 

0 0 0.1 0.1 $2.98 $0.00 $2.98 57 5.7 $169.63 

Total 0 0.02 0.1 0.12 $4.27 $0.00 $4.27 57 6.84 $243.40 

Imports to the U.S. from OECD Countries

Importers

Sign movement/tracking 

document and provide copy to 

OECD Country exporter, EPA, 

and competent authority of the 

country of export

0.08 0 0.25 0.33 $16.37 $0.00 $16.37 36 11.88 $589.37 

Maintain copy of signed 

movement/tracking document 

0 0 0.1 0.1 $3.39 $0.00 $3.39 36 3.6 $121.86 

Prepare and provide certificate 

of recovery to OECD Country 

exporter, EPA, and competent 

authority of the country of 

export 

0 0.2 0.25 0.45 $21.40 $0.36 $21.76 36 16.2 $783.52 

Obtain certificate of recovery 

from the U.S. R1-R11 facility 

0 0 0.16 0.16 $5.42 $0.90 $6.32 36 5.76 $227.38 
44

Activity

Cost per Shipment Cost for All Shipments

Managerial 

Staff 

Hours

Technical 

Staff 

Hours

Clerical 

Staff 

Hours

Total 

Hours

Labor 

Costa

O&M

Costb

Total 

Cost

Number of 

Shipmentsc

Total 

Hours

Total Cost

Provide copy of certificate of 

recovery to EPA and the 

competent authority of the 

country of export

0 0 0.16 0.16 $5.42 $0.24 $5.66 36 5.76 $203.62 

Total 0.08 0.2 0.92 1.2 $51.99 $1.50 $53.49 36 43.2 $1,925.74 

a

 Based on hourly rates discussed in Section 3.1 of the Cost Assessment document for the final rule.

b

 Based on materials costs discussed in Section 3.2 of the Cost Assessment document for the final rule

c

 Based on shipment estimates discussed in Section 3.3 of the Cost Assessment document for the final rule.
45

Exhibit 6

OECD Revisions - Return of Wastes

Activity

Cost per Shipment Cost for All Shipments

Managerial 

Staff

Hours

Technical 

Staff 

Hours

Clerical 

Staff 

Hours

Total 

Hours

Labor 

Costa

O&M

Costb

Total 

Cost

Number of 

Shipmentsc

Total 

Hours

Total 

Cost

Exports from the U.S. to OCED Countries

EPA

Receive and maintain 

notification of the return of 

the waste provided by the 

competent authority of the 

country of import 

0 0 0.1 0.1 $2.98 $0.00 $2.98 1 0.1 $2.98 

Imports to the U.S. from OCED Countries 

U.S. Importer

Prepare and Submit 

Notification to EPA. (U.S. 

importer must inform EPA 

[ ....] of the need to return the 

shipment. Assumes: importer 

completes return within 90 

days, return shipment does 

not cross any new transit 

country.)

0 0.2 0.25 0.45 $21.40 $0.44

(mailed)

$21.84 1 0.45 $21.84

EPA

Inform the competent 

authorities of the countries of 

export and transit about the 

return of the wastes 

0 0.5 0 0.5 $25.67 $0.12 

(FAX)

$25.79 1 0.5 $25.79 

Total 0 0.7 0.35 1.05 $50.05 $0.56 $50.61 2 1.05 $50.61

a

 Based on hourly rates discussed in Section 3.1 of the Cost Assessment document for the final rule.

b

 Based on materials costs discussed in Section 3.2 of the Cost Assessment document for the final rule. Plus, assumes April 2009 first-class postage of $0.42 plus 

$0.01 for envelop and $0.01 for importer to mail one sheet of paper.

c

 Based on shipment estimates discussed in Section 4.1.5 of the Cost Assessment document for the final rule.
46

Exhibit 7

SLAB Revisions - Reading the Rule

(In the first year of Rule Implementation Only)

Activity

Cost per Entity Cost of All Entities

Managerial 

Staff 

Hours

Technical 

Staff 

Hours

Clerical 

Staff 

Hours

Hours Labor 

Costa

O&M

Costb

Total Cost Number of 

EntitiesC

Total 

Hours

Total Cost 

Reading the Regulations

U.S. Exporters 1 2.5 0 3.5 $260.64 $0.00 $260.64 1,141 3,993.50 $297,384.54

U.S. Transporters 1 2.5 0 3.5 $260.64 $0.00 $260.64 571 1,998.50 $148,822.59

Total 1,712 5,992.00 $446,207.12

a

 Based on hourly rates discussed in Section 3.1 of the Cost Assessment document for the final rule.

b

 Based on materials costs discussed in Section 3.2 of the Cost Assessment document for the final rule.

c

 Based on universe assumptions discussed in Sections 3.4 and 4.7 of the Cost Assessment document for the final rule.
47

Exhibit 8

SLAB Revisions – Notification

For SLAB Exports to non-OECD Countries, Canada and Mexico

Activity

Cost per Notice Cost of All Notices

Managerial 

Staff 

Hours

Technical 

Staff 

Hours

Clerical 

Staff 

Hours

Hours Labor 

Costa

O&M

Costb

Total 

Cost

Number 

of 

NoticesC

Total 

Hours

Total Cost 

Notification

U.S. Exporters

Prepare and submit notification 0 1.5 0 1.5 $97.07 $0.42 $97.49 668 1,002.00 $65,119.98

Total 0 1.5 0 1.5 $97.07 $0.42 $97.49 668 1002.00 $65,119.98

EPA

Receive and process 

notification

0 1 0 1 $51.33 $0.00 $51.33 668 668.00 $34,288.44

Prepare and transmit 

confirmation of receipt to U.S. 

exporter

0 0 0.25 0.25 $7.44 $0.12 $7.56 668 167.00 $5,050.08

Forward notification to the 

competent authorities of the 

countries of import and transit 

0 0 0.16 0.16 $4.76 $0.24 $5.00 668 106.88 $3,341.07

Receive and process 

Acknowledgement of Receipt 

from the competent authority of 

the country of import

0 0 0.25 0.25 $7.44 $0.00 $7.44 668 167.00 $4,969.92

Receive and process 

consent/objection from the 

competent authorities of the 

countries of import and transit 

0 0 0.16 0.16 $4.76 $0.00 $4.76 668 106.88 $3,180.75

Forward written 

Acknowledgement of Consent 

or objection to U.S. exporter 

0 0 0.25 0.25 $7.44 $0.12 $7.56 668 167.00 $5,050.08

Total 0 1 1.07 2.07 $83.17 $0.48 $83.65 668 1,382.76 $55,880.34

a

 Based on hourly rates discussed in Section 3.1 of the Cost Assessment document for the final rule.

b

 Based on materials costs discussed in Section 3.2 of the Cost Assessment document for the final rule.

c

 Based on universe assumptions discussed in Section 3.4 of the Cost Assessment document for the final rule.
48

Exhibit 9

SLAB Revisions – Renotification

For SLAB Exports to non-OECD Countries, Canada and Mexico

Activity

Cost per Notice Cost of All Notices

Managerial 

Staff 

Hours

Technical 

Staff 

Hours

Clerical 

Staff 

Hours

Hours Labor 

Costa

O&M

Costb

Total Cost Number of 

NoticesC

Total 

Hours

Total Cost 

Renotification

U.S. Exporters

Collect specific changes 0 0.5 0 0.5 $32.36 $0.00 $32.36 43 21.5 $1,391.27

Prepare and submit 

renotification

0.1 0 0.5 0.6 $26.81 $0.42 $27.23 43 25.8 $1,170.93

Total 0.1 0.5 0.5 1.1 $59.17 $0.42 $59.59 43 47.3 $2,562.20

EPA

Receive and process 

notification

0 0.5 0 0.5 $25.67 $0.00 $25.67 43 21.5 $1,103.60

Prepare and transmit 

confirmation of receipt 

to U.S. exporter

0 0 0.25 0.25 $7.44 $0.12 $7.56 43 10.75 $325.08

Forward notification to 

the competent 

authorities of the 

countries of import and 

transit 

0 0 0.16 0.16 $4.76 $0.24 $5.00 43 6.88 $215.07

Receive and process 

Acknowledgement of 

Receipt from the 

competent authority of 

the country of import

0 0 0.25 0.25 $7.44 $0.00 $7.44 43 10.75 $319.92

Receive and process 

consent/objection from 

the competent 

authorities of the 

countries of import and 

transit 

0 0 0.16 0.16 $4.76 $0.00 $4.76 43 6.88 $204.75
49

Activity

Cost per Notice Cost of All Notices

Managerial 

Staff 

Hours

Technical 

Staff 

Hours

Clerical 

Staff 

Hours

Hours Labor 

Costa

O&M

Costb

Total Cost Number of 

NoticesC

Total 

Hours

Total Cost 

Forward written 

Acknowledgement of 

Consent or objection to 

U.S. exporter 

0 0 0.25 0.25 $7.44 $0.12 $7.56 43 10.75 $325.08

Total 0 0.5 1.07 1.57 $57.51 $0.48 $57.99 43 65.71 $2,493.49

a

 Based on hourly rates discussed in Section 3.1 of the Cost Assessment document for the final rule.

b

 Based on materials costs discussed in Section 3.2 of the Cost Assessment document for the final rule.

c

 Based on universe assumptions discussed in Section 3.4 of the Cost Assessment document for the final rule.
50

Exhibit 10

SLAB Revisions - Annual Report

For SLAB Exports to non-OECD Countries, Canada and Mexico

Activity

Cost per Entity Cost for all Entities

Managerial

Staff 

Hours

Technical 

Staff 

Hours

Clerical 

Staff 

Hours

Hours Labor 

Costa

O&M

Costb

Total Cost Number of 

EntitiesC

Total 

Hours

Total Cost 

Annual Report

Large U.S. Exporters

Research specific 

export information

0 1 1 2 $98.56 $0.00 $98.56 613 1,226.00 $60,417.28

Prepare and submit 

report

0.1 1 0.3 1.4 $84.75 $4.24 $88.99 613 858.20 $54,551.48

Small U.S. Exporters

Research specific 

export information

0 0.5 0.5 1 $49.28 $0.00 $49.28 27 27.00 $1,330.56

Prepare and submit 

report

0.1 0.5 0.5 1.1 $59.17 $4.24 $63.41 27 29.70 $1,711.96

Total 0.2 3 2.3 5.5 $291.76 $8.48 $300.24 640 2,140.90 $118,011.29

EPA

Receive and record 

report

0 0.1 0.5 0.6 $20.01 $0.00 $20.01 640 384.00 $12,808.32

Total 0 0.1 0.5 0.6 $20.01 $0.00 $20.01 640 384.00 $12,808.32

a

 Based on hourly rates discussed in Section 3.1 of the Cost Assessment document for the final rule.

b

 Based on materials costs discussed in Section 3.2 of the Cost Assessment document for the final rule.

c

 Based on universe assumptions discussed in Section 3.4 of the Cost Assessment document for the final rule.
51

Exhibit 11

SLAB Revisions - Additional Report

For SLAB Exports to non-OECD Countries, Canada and Mexico

Activity

Cost per Entity Cost for all Entities

Managerial 

Staff 

Hours

Technical 

Staff 

Hours

Clerical 

Staff 

Hours

Hours Labor 

Costa

O&M

Costb

Total Cost Number of 

ReportsC

Total 

Hours

Total Cost 

Additional Report

U.S. Exporters

Collect and provide 

additional information

0 0.5 0.5 1 $49.28 $4.24 $53.52 2 2 $107.04

Total 0 0.5 0.5 1 $49.28 $4.24 $53.52 2 2 $107.04

EPA

Receive and process 

Request for Additional 

Information from the 

competent authority of 

the country of import

0 0 0.25 0.25 $7.44 $0.00 $7.44 2 0.5 $14.88

Forward request for 

additional information to 

U.S. Exporter

0 0 0.16 0.16 $4.76 $0.12 $4.88 2 0.32 $9.76

Receive and process 

additional info from U.S. 

Exporter

0 0 0.25 0.25 $7.44 $0.00 $7.44 2 0.5 $14.88

Forward additional info 

to countries of import 

and transit

0 0 0.16 0.16 $4.76 $0.24 $5.00 2 0.32 $10.00

Total 0 0 0.82 0.82 $24.40 $0.36 $24.76 2 1.64 $49.53

a

 Based on hourly rates discussed in Section 3.1 of the Cost Assessment document for the final rule.

b

 Based on materials costs discussed in Section 3.2 of the Cost Assessment document for the final rule.

c

 Based on universe assumptions discussed in Section 3.4 of the Cost Assessment document for the final rule.
52

Exhibit 12

SLAB Revisions - Acknowledgement of Consent to Transporter

For SLAB Exports to non-OECD Countries, Canada and Mexico

Activity

Cost per Shipment Cost of All Shipments

Managerial 

Staff 

Hours

Technical 

Staff 

Hours

Clerical 

Staff 

Hours

Hours Labor 

Costa

O&M

Costb

Total Cost Number of 

ShipmentsC

Total 

Hours

Total Cost 

U.S. Exporter Provides Copy of the EPA Acknowledgement of Consent to Transporter

Find consent document 0 0 0.17 0.17 $5.75 $0.00 $5.75 16,154 2,746.18 $92,958.19

Copy consent 

document

0 0 0.08 0.08 $2.81 $0.22 $3.03 16,154 1,340.78 $48,939.35

Total 0 0 0.25 0.25 $8.56 $0.22 $8.78 16,154 4,086.96 $141,897.54

a

 Based on hourly rates discussed in Section 3.1 of the Cost Assessment document for the final rule.

b

 Based on materials costs discussed in Section 3.2 of the Cost Assessment document for the final rule.

c

 Based on universe assumptions discussed in Section 3.4 of the Cost Assessment document for the final rule.
53

Exhibit 13

SLAB Revisions - Recordkeeping

For SLAB Exports to non-OECD Countries, Canada and Mexico

Activity

Cost per Entity Cost of All Entities

Managerial 

Staff 

Hours

Technical 

Staff 

Hours

Clerical 

Staff 

Hours

Hours Labor 

Costa

O&M

Costb

Total Cost Number of 

EntitiesC

Total 

Hours

Total Cost 

U.S. Exporter Recordkeeping

File and maintain 

necessary documents

0 0 0.25 0.25 $8.46 $0.00 $8.46 640 160.00 $5,416.00

Total 0 0 0.25 0.25 $8.46 $0.00 $8.46 640 160.00 $5,416.00

a

 Based on hourly rates discussed in Section 3.1 of the Cost Assessment document for the final rule.

b

 Based on materials costs discussed in Section 3.2 of the Cost Assessment document for the final rule.

c

 Based on universe assumptions discussed in Section 3.4 of the Cost Assessment document for the final rule.
54

Exhibit 14

Import Consent Documentation - Receiving Facility Submission to EPA

Activity

Cost Per Shipment Cost for All Shipments

Managerial 

Staff 

Hours 

Technical 

Staff 

Hours 

Clerical 

Staff 

Hours 

Total 

Hours

Labor 

Costa

O&M

Costb

Total Cost Number of 

Shipmentsc

Total 

Hours

Total Cost 

Receiving Facility Submission to EPA

Importers

Find Consent Document 0 0 0.17 0.17 $5.75 $0.00 $5.75 2,712 461.04 $15,606.20 

Match Consent Document 

to Manifest

0 0 0.17 0.17 $5.75 $0.00 $5.75 2,712 461.04 $15,606.20

Copy Consent Document 0 0 0.083 0.083 $2.81 $0.22 $3.03 2,712 225.10 $8216.14

Submit Consent to EPA 0 0 0 0 $0.00 $0.00 $0.00 2,712 0 $0.00 

Total 0 0 0.42 0.42 $14.32 $0.22 $14.54 2,712 1,147.18 $39,428.55

EPA 

Receive and File Consent 

Document

0 0 0.083 0.083 $2.47 $0.00 $2.47 2,712 225.10 $6,698.86

Total 0 0 0.083 0.083 $2.47 $0.00 $2.47 2,712 225.10 $6,698.86

a

 Based on hourly rates discussed in Section 3.1 of Cost Assessment document for the final rule.

b

 Based on materials costs discussed in Section 3.2 of the Cost Assessment document for the final rule.

c

 Based on universe assumptions discussed in Section 3.5 and Section 4.3.1 of the Cost Assessment document for the final rule.
55

Exhibit 15

Total Annual Estimated Respondent Burden

ICR Name ICR 

Number

Total 

Hours/Year

Labor 

Cost/Year

Capital 

Cost/Year

O&M

Cost/Year

Total 

Cost/Year

OECD Revisions:

Reading the Rule (Year 1 only) 2308.01 63.00 $4,793.88 0 $0.00 $4,793.88 

Exemption for Wastes Destined for Laboratory 

Analysis 2308.01 -43.00 -$2,182.63 0 -$42.40 -$2,225.14

Certificate of Recovery 2308.01 210.70 $8,959.11 0 $106.56 $9,065.67 

Exchange and Accumulation Recovery Operations 2308.01 44.34 $1,945.51 0 $54.00 $1,999.51 

Return of Wastes 2308.01 0.45 $21.40 0 $0.44 $21.84

Subtotal 275.49 $13,537.26 $0.00 $118.60 $13,655.76

SLAB Revisions -- for SLAB Exports to non-OECD Countries, Canada and Mexico:

Reading the Rule (Year 1 only) 2308.01 5,990.00 $446,207.12 0 $0.00 $446,207.12

Notification 2308.01 1,002.00 64,839.42 0 $280.56 $65,119.98 

Renotification 2308.01 47.30 $2,544.14 0 $18.06 $2,562.20 

Annual Report 2308.01 2,140.90 $115,297.69 0 $2,713.60 $118,011.29 

Additional Report 2308.01 2.00 $98.56 0 $8.48 $107.04 

Acknowledgement of Consent to Transporter 2308.01 4,086.96 $138,343.66 0 $3,553.88 $141,897.54 

Recordkeeping 2308.01 160.00 $5,416.00 0 $0.00 $5,416.00 

Subtotal 13,431.16 $772,746.59 $0.00 $6,574.58 $779,321.17

Import Consent Documentation:

Receiving Facility Submission to EPA 2308.01 1,147.18 $38,831.91 0 $596.64 $39,428.55

Subtotal 1,147.18 $38,831.91 $0.00 $596.64 $39,428.55

TOTAL for Year 1 14,853.83 $825,115.76 $0.00 $7,289.82 $832,405.47

TOTAL for Year 2 and beyond 8,798.83 $374,114.76 $7,289.82 $381,404.47

THREE-YEAR TOTAL(Year 1+Year 2+Year 3): 32,451.48 $1,573,345.27 $21,869.46 $1,595,214.41

THREE-YEAR AVERAGE(Year 1+Year 2+Year 3): 10,817.16 $524,448.42 $7,289.82 $531,738.14
56

Exhibit 16

Summary of New and Existing Annual Respondent Hour and Cost Burden

ICR Name ICR 

Number

Total 

Hours/Year

Labor 

Cost/Year

Capital 

Cost/Year

O&M 

Cost/Year

Total 

Cost/Year

New Paperwork Requirements

Revisions to the Requirements for Transboundary Shipments of Wastes 

between OECD Countries, to the Requirements for Export Shipments 

of Spent Lead Acid Batteries, to the Requirements on Submitting 

Exception Reports for Export Shipments of Hazardous Wastes, and to 

the Requirements for Import Shipments of Hazardous Wastes

2308.01 10,817 $524,448 $0 $7,290 $531,738

Existing Paperwork Requirements

Hazardous Waste Generator Standards* 820.1

-- Exporter Requirements 4,389 $129,460 ----- $1,401 $130,861 

-- Importer-Exporter Requirements OECD and Bilateral 324 $9,678 ----- $182 $9,859 

General Hazardous Waste Facility Standards** 1571.08

-- Foreign Shipment Import Report (264.12(a) and 265.12(a)) 166 $188 0 0.33 $10,418 

Notification of Regulated Waste Activity*** 0261.15 100,307 $9,454,718 0 $234,843 $9,689,561 

Subtotal 105,186 $9,594,044 $0 $236,426 $9,840,699

TOTAL 116,003 $10,118,492 $0 $243,716 $10,372,437

* See Exhibit 9 of the Supporting Statement for EPA Information Collection Request Number 0820.10 Hazardous Waste Generator Standards, January 2008

** See Exhibit 1 of the Supporting Statement for EPA Information Collection Request 1571.08 "General Hazardous Waste Facility Standards," February 2006

*** See Exhibit 3 of the Supporting Statement for EPA Information Collection Request Number 261.15 "Notification of Regulated Waste Activity," January 2006
57

Exhibit 17

Total Annual Estimated Agency Burden

ICR Name ICR 

Number

Total 

Hours/Year

Labor 

Cost/Year

Capital 

Cost/Year

O&M

Cost/Year

Total 

Cost/Year

OECD Revisions:

Reading the Rule 2308.01 0.00 0 0 0 0

Exemption for Wastes Destined for Laboratory Analysis 2308.01 -39.20 -$1,659.79 0 -$7.20 -$1,666.96

Certificate of Recovery 2308.01 77.50 $2,306.40 0 $0.00 $2,306.40 

Exchange and Accumulation Recovery Operations 2308.01 5.70 $169.63 0 $0.00 $169.63 

Return of Wastes 2308.01 0.60 $28.64 0 $0.12 $28.76 

Subtotal 44.60 $844.88 $0.00 -$7.08 $837.83 

SLAB Revisions -- for SLAB Exports to non-OECD Countries, Canada and Mexico:

Reading the Rule 2308.01 0.00 0 0 0 0

Notification 2308.01 1,382.76 $55,559.70 0 $320.64 $55,880.34 

Renotification 2308.01 67.51 $2,472.85 0 $20.64 $2,493.49 

Annual Report 2308.01 384.00 $12,808.32 0 $0.00 $12,808.32 

Additional Report 2308.01 1.64 $48.81 0 $0.72 $49.53 

Acknowledgement of Consent to Transporter 2308.01 0.00 0 0 0 0

Recordkeeping 2308.01 0.00 0 0 0 0

Subtotal 1,835.91 $70,889.68 $0.00 $342.00 $71,231.68 

Import Consent Documentation:

Receiving Facility Submission to EPA 2308.01 225.10 $6,698.86 0 $0.00 $6,698.86

Subtotal 225.10 $6,698.86 $0.00 $0.00 $6,698.86

TOTAL 2,105.61 $78,433.41 $0.00 $334.92 $78,768.37