1

SUPPORTING STATEMENT FOR 

EPA INFORMATION COLLECTION REQUEST NUMBER 2519.01 

“HAZARDOUS WASTE EXPORT-IMPORT REVISIONS RULE” 

September 2015 

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 ............................1 

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

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

2. NEED FOR AND USE OF THE COLLECTION ...................................................7 

 2(a) Need and Authority for the Collection .........................................................7 

 2(b) Practical Utility and Users of the Data ........................................................7 

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA ...............................................................................................................7 

 3(a) Nonduplication .............................................................................................7 

 3(b) Public Notice ................................................................................................8 

 3(c) Consultations................................................................................................8 

 3(d) Effects of Less Frequent Collection .............................................................8 

 3(e) General Guidelines .......................................................................................8 

 3(f) Confidentiality .............................................................................................8 

 3(g) Sensitive Questions ......................................................................................9 

4. THE RESPONDENTS AND THE INFORMATION REQUESTED .....................9 

 4(a) Respondents and NAICS Codes ..................................................................9 

 4(b) Information Requested ...............................................................................10 

5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, 

COLLECTION METHODOLOGY, AND INFORMATION 

MANAGEMENT ...................................................................................................18 

 5(a) Agency Activities .......................................................................................18 

 5(b) Collection Methodology and 

Management 19 

5(c) Small Entity Flexibility ..............................................................................19 

 5(d) Collection Schedule ...................................................................................20 

6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION ...20 

 6(a) Estimating Respondent Burden..................................................................20 

 6(b) Estimating Respondent Costs ....................................................................21 

 6(c) Estimating Agency Burden and Costs .......................................................22 

 6(d) Estimating the Respondent Universe and Total Burden and Costs ...........22 

 6(e) Bottom Line Burden Hours and Costs .......................................................27 

 6(f) Reasons for Change in 

Burden 28 

6(g) Burden Statement .......................................................................................29 
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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 "Hazardous Waste Export-Import Revisions 

(Proposed Rule)" EPA ICR Number 2519.01, OMB Number 2050-NEW. 

1(b) Short Characterization 

Since March 1992, OECD member countries have regulated the international movement 

of hazardous wastes destined for recovery under Council Decision C(92)39/FINAL. EPA’s April 

1996 Imports and Exports of Hazardous Waste Final Rule implements OECD’s Council 

Decision C(92)39/FINAL in the United States under RCRA authority, under 40 CFR Part 262, 

Subpart H.1

 While that rule codifies the OECD requirements for U.S. imports and exports of 

hazardous waste with OECD countries, shipments to Canada and Mexico are also covered under 

separate bilateral agreements. RCRA regulatory requirements for exports to Canada, Mexico, 

and non-OECD countries are under 40 CFR Part 262, Subpart E, and the corresponding import 

requirements for shipments from these countries are under 40 CFR Part 262, Subpart F. In 2004, 

in order to improve some of its provisions and enhance harmonization with the Basel 

Convention, OECD updated its rule under Council Decision C(2001)107/FINAL, as amended by 

C(2004)20 and further amendments in November 2005 and November 2008. In 2008, EPA 

developed the Proposed 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 to implement these updates and strengthen controls on SLABs 

by making their export subject to subpart E export regulations, if being shipped to Canada, 

Mexico, or non-OECD countries, or subject to subpart H OECD regulations, if being shipped to 

OECD countries other than Canada or Mexico. The final rule for these changes was issued in 

2010. Because domestic shipment of SLABs for recycling is exempted from RCRA manifest 

requirements, export shipments of SLABs were also exempted from RCRA manifest 

requirements. But export shipments of SLABs subject to subpart H OECD requirements were 

subject to OECD movement document requirements under the changes in the 2010 rule. 

Since the 2010 rulemaking, however, EPA and several non-governmental organizations 

have raised concerns over the lack of reporting and insufficient environmental and occupational 

health controls associated with transboundary movement of hazardous wastes, most notably 

 

1

 U.S. EPA 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, Final Rule, Federal Register, Vol. 61, No. 72, April 12, 1996. 
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regarding exports of SLABs to Canada and Mexico.2,3,4 To address these concerns, EPA is 

proposing to make all U.S. imports and exports of hazardous waste, including those with 

countries outside of OECD, subject to standards equivalent to those promulgated in 40 CFR Part 

262, Subpart H in the 2010 rulemaking. In addition, EPA is proposing to mandate the electronic 

submission of required documents, which is expected to improve data availability and quality. 

Better data will help the United States and other countries control the environmental and health 

risks associated with hazardous waste movement, processing, and disposal. 

The pertinent details of the proposed rule are outlined below. For further information 

regarding the historical context and details of this rulemaking, please refer to the Preamble to the 

proposed rule. 

REGULATORY CHANGES/AMENDMENTS 

 A. Changes to 40 CFR Part 262, Subparts E and F 

The proposed rule will regulate hazardous waste shipments with Mexico, Canada and non-OECD 

countries in a manner more consistent with regulations currently in place for shipments with other OECD 

member countries under 40 CFR Part 262, Subpart H. Many of the regulatory changes described below 

therefore do not alter the requirements in Subpart H associated with each provision, but rather adjust the 

types of entities held to each requirement by making entities currently subject to Subpart E and F 

requirements subject to Subpart H requirements. Changes to requirements for shipments currently subject 

to 40 CFR Part 262, Subpart E (i.e., exports to Canada, Mexico, and non-OECD countries) and Subpart F 

(i.e., imports from Canada, Mexico, and non-OECD countries) include the following: 

(1) Exporters of hazardous waste to Canada, Mexico, and non-OECD countries will 

be required to submit additional information with each export notice. 

This additional information includes an e-mail address and fax number for each listed 

party on the notice, all anticipated transporters for the shipments, all anticipated 

export ports in the United States, any interim facilities to be used during the transfer 

of waste, and the OECD waste codes and recycling or disposal operation codes for all 

waste streams to be shipped. Exporters to other OECD countries are already required 

to submit this information, and will therefore experience no change in their cost 

burden as a result of the proposed rule. 

(2) Importers of RCRA hazardous wastes not treated as hazardous waste exports by 

the country of export will need to submit notices to EPA on behalf of foreign 

 

2

 OECD (2012), Illegal Trade in Environmentally Sensitive Goods, OECD Trade Policy Studies, OECD Publishing, accessed at 

http://dx.doi.org/10.1787/9789264174238-en on November 12, 2014. 

3

 Occupational Knowledge International and Fronteras Comunes, Exporting Hazards: U.S. shipments of used lead batteries to Mexico take 

advantage of lax environmental and worker health regulations, June 2011, accessed at 

http://www.okinternational.org/docs/Exporting%20Hazards_Study_100611v5.pdf on November 12, 2014. 

4

 Secretariat of the Commission for Environmental Cooperation, Hazardous Trade? An Examination of US-generated Spent Lead-Acid Battery Exports 

and Secondary Lead Recycling in Canada, Mexico, and the United States, April 2013, accessed at http://www3.cec.org/islandora/en/item/11220-

hazardous-trade-examination-us-generated-spent-lead-acid-battery-exports-and on October 21, 2014. 
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exporters. 

§262.82(a)(2)(ii) requires that hazardous waste shipments fulfill all regulatory 

requirements regardless of the designation of the waste in the country of export. 

§262.82(a)(2)(ii)(B) specifies that export notice requirements usually assigned to 

foreign exporters will become the duty of U.S. import facilities receiving shipments 

of waste. This requirement already applies to shipments of waste from other OECD 

countries and will be required for import shipments from Canada, Mexico, or nonOECD countries. This new U.S. requirement will not affect shipments from Canada 

as Canadian regulations already require export notices whenever the country of 

import controls the proposed shipment as hazardous waste, but will affect import 

shipments from Mexico and non-OECD countries. 

 

(3) For export annual reports to EPA, exporters to Canada, Mexico, and non-OECD 

countries must list OECD waste codes for all shipments in addition to RCRA 

waste codes, and must list DOT/ID numbers in place of DOT hazard classes. 

Exporters of hazardous waste to OECD countries must already comply with the first 

requirement in Subpart H. Exporters to Canada, Mexico, and non-OECD counties 

will be affected by the second requirement, but as it replaces an existing data item 

being collected, the net impact of the second requirement will be zero.

(4) Contracts must be signed between exporters and importers of hazardous waste 

and foreign facilities specifying the parties relevant to each shipment and the 

various legal responsibilities of each party involved. 

Exporters and importers of hazardous waste with OECD countries are already held to 

this requirement under subpart H. Exporters and importers of hazardous waste with 

Canada, Mexico and non-OECD countries will now be subject to this new U.S. 

requirement, but U.S. exporters and importers of waste with Canada will not be 

impacted as Canadian regulations already require contracts between the Canadian 

facility and the foreign facility. 

 

(5) Exception reports can be based on either RCRA manifests or OECD movement 

documents. 

Currently, exception reports under Subpart E are only based off of RCRA manifests. 

This change will potentially impact export shipments of universal waste and SLABs 

to Canada, Mexico, and non-OECD countries that are partially or wholly rejected by 

the foreign receiving facility. 

(6) Exporters and importers must ensure that a movement document accompanies 

all shipments of hazardous waste. 

The movement document must include a signed certification, as well as all 

information required for notification. For shipments to and from Canada, exporters 
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and importers may use the existing Canadian movement document they are already 

required to use under Canadian regulations to fulfill this requirement. Similarly, 

exporters to OECD countries and importers receiving waste from OECD countries for 

recycling (with the exception of Canada and Mexico) are already required to 

complete this document. Therefore, this requirement will only impact exporters and 

importers exchanging waste with Mexico and non-OECD countries. 

(7) U.S. receiving facilities must send a copy of the signed OECD movement 

document to EPA, the foreign exporter of the waste, and the relevant authorities 

of the exporting country. 

This requirement must be completed within three days of receiving a shipment of 

hazardous waste. Importers must also maintain a signed copy of the movement 

document for three years. Importers receiving waste from other OECD countries must 

already comply with this requirement. Similarly, importers receiving waste from 

Canada can use the Canadian movement document they are already required to send 

to the Canadian exporter under Canadian regulations to fulfill this requirement, so the 

expected net burden will be sending copies to EPA and to Environment Canada. 

Importers receiving shipments from Mexico and non-OECD countries will experience 

the full impact of this change, as they currently do not send copies of such a 

movement document to anyone. 

(8) U.S. receiving facilities must prepare and send a confirmation of recovery or 

disposal to EPA, the exporter, and the relevant authority in the country of 

export for each shipment received. 

Importers receiving shipments from OECD countries are already subject to this 

requirement under existing U.S. regulations, and will therefore not experience a 

change in burden as a result of the proposed rule. U.S. importers receiving shipments 

from Canada are already required to prepare and send a confirmation to the foreign 

exporter, and therefore will only incur costs to send confirmations to EPA and 

Environment Canada. U.S. importers receiving shipments from Mexico and nonOECD countries will experience the full impact of this change as they are not 

currently required to send confirmations of recovery or disposal to anyone. 

 

(9) U.S. exporters must maintain a copy of the movement document and the 

confirmation of recovery or disposal from the foreign importing facility for three 

years. 

Exporters to OECD countries are already subject to this requirement under existing 

regulations, and will therefore not experience a change in burden as a result of the 

proposed rule. Exporters to Canada, Mexico, and non-OECD countries will be 

affected by this change. 

(10) Return of wastes. 
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When a manifested shipment of hazardous waste cannot be completed, the primary 

exporter must (1) instruct the transporter to either return the shipment to the exporter 

or to an alternative facility in the United States, and (2) submit an exception report to 

EPA. The proposed rule does not change any of these requirements with the 

exception of allowing the alternate facility to be in the country of import if allowed 

by the country of import, specifying that the instructions to the transporter be made 

via mail, e-mail, or fax (so that a record of the instructions exist), and requiring that 

the shipments be returned within 90 days of receiving notification from the country of 

import or transit. 

(11) Transnational shipments with Canada, Mexico, and non-OCED countries that 

are exempt from export and import requirements as wastes destined for 

laboratory analysis are subject to additional weight limits. 

Under existing regulations in 40 CFR Part 261, domestic shipments of hazardous 

waste sent for laboratory analysis are exempt from hazardous waste requirements if 

they fall within certain weight limits. Existing weight limits for exempted waste 

shipments range from 1kg for acute hazardous waste to 10,000kg of media 

contaminated with non-acute hazardous waste. Exporters and importers shipping 

hazardous waste samples for laboratory analysis to and from OECD countries are 

already subject to the additional limitation that the samples weigh no more than 25kg 

to be exempt from Subpart H export and import requirements (e.g., notice, movement 

document). The proposed rule makes exporters and importers shipping samples for 

laboratory analysis to and from Canada, Mexico, and non-OECD countries subject to 

the additional limitation of samples weighing no more than 25kg to be exempt from 

export and import requirements. As a result, currently-exempt shipments may no 

longer be exempt. EPA is requesting comment on the number of currently exempt 

shipments that will be impacted by this change. 

(12) Transporter manifesting requirements. 

Exporters shipping wastes to any country subject to RCRA manifesting requirements 

will no longer be required to provide an extra copy of the manifest to the transporter, 

and the transporter will no longer be required to give that copy to the Customs officer 

at the port of exit at time of departure. This change will affect all export shipments 

currently subject to Subpart E or H. This paper submittal requirement is being 

dropped because it will be duplicative to CBP’s Automated Export System (AES) 

filing and information provided in the eventual submittal of the OECD movement 

document by the foreign receiving facility to confirm receipt. 

 B. Changes to 40 CFR Part 262, Subpart H 

(1) Exporters will no longer be required to submit a copy of EPA’s 

Acknowledgment of Consent to transporters. 

Under existing regulations in Subpart E, exporters shipping to Canada, Mexico, and 

non-OECD countries must provide a copy of EPA’s Acknowledgment of Consent to 
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the transporter for each hazardous waste shipment. The proposed rule eliminates this 

requirement. Exports to OECD countries other than Canada and Mexico will not be 

impacted by this change. 
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(2) Obtain EPA Identification Numbers 

The proposed rule will require all recognized traders involved in the arrangement of 

transportation of hazardous waste to obtain an EPA ID number.5 EPA assumes that 

one percent of all exporters and importers are recognized traders, and request 

comment on the accuracy of this assumption. 

(3) Exporters and importers must comply with electronic reporting requirements 

using EPA’s hazardous waste import/export database.

The proposed rule establishes requirements for electronic reporting for exporters and 

importers of hazardous waste and exempted waste in part 261 subject to export 

conditions (i.e., cathode ray tubes (CRTs) being exported for recycling). Many of the 

activities required for these entities will be determined by instructions associated with 

EPA’s electronic document receiving system. Under the proposed rule, EPA plans to 

employ the already developed agency-wide receiving system, the Central Data 

Exchange (CDX), for the electronic submittal of required forms. The electronic 

system guides users through the registration and reporting procedures. Electronic 

submittal is required for all exporters and importers; however, a waiver is available 

for companies that meet certain conditions specified by EPA (i.e., lack of access to 

broadband internet or other unique circumstances). Each individual entity required to 

submit documents electronically will need to register to use the system. The proposed 

rule will require electronic submittal of export notices, import notices (where the 

shipment is not considered hazardous in the country of export), confirmation of 

receipt for import manifests, confirmation of recovery/disposal, movement 

documents, exception reports, annual reports, and notification for return of wastes. 

Each submittal will require that the exporter or importer sign each document 

electronically. 

(4) Exporters must file additional EPA data elements as part of their AES filing 

requirements under 15 CFR 30.4 (this requirement is also being added to the 

CRT export requirements in 40 CFR 261.39(a)(5)). 

Under existing U.S. Census Bureau regulations, exporters of waste subject to RCRA 

consent requirements must enter shipment data into the U.S. Census Bureau’s AES 

for each shipment. Under the proposed rule, exporters will be required in Subpart H 

to fill in two additional fields for the export license and EPA consent number, and 

conditionally required to fill in three additional fields related to the RCRA hazardous 

waste manifest tracking number, exported quantity, and reporting units if the existing 

AES-required reporting is not in units of weight (kg) or volume (L). It is unknown 

what percentage of the filings are expected to require the conditional data fields, so 

EPA is requesting comment from exporters on what export shipments of waste are 

not required to report in units of weight or volume in AES. 

 

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 A recognized trader is a person domiciled in the United States, who acts to arrange and facilitate transboundary movements of wastes destined 

for recovery or disposal operations, either by purchasing from and subsequently selling to U.S. and foreign facilities, or by acting under 

arrangements with a U.S. waste facility to arrange for the export or import of the wastes. 
8

This provision would also set new requirements for CRTs exported for recycling 

under 40 CFR 261.39. EPA estimates that these exporters are already filing in AES 

for all shipments under current U.S. Census Bureau regulations. This change would 

require the filing of two to five additional fields in AES, as would filings for 

hazardous waste export shipments subject to Part 262 export requirements. 

2. NEED FOR AND USE OF THE COLLECTION 

2(a) Need and Authority for the Collection 

The requirements covered in this ICR are necessary for EPA to oversee the international 

trade of hazardous wastes. 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. 

 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, receiving facility, transporter, and recognized trader 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

Most of the information required by the regulations covered by this ICR is not available 

from any source but the respondents. In certain occasions, such as the notification of intent to 

export hazardous waste, EPA allows the primary exporter to submit one notice that covers 

activities over a period of twelve months. 

Except as described below, the proposed rule 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. 
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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 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. 

 3(b) Public Notice 

In compliance with the Paperwork Reduction Act of 1995, EPA will open a 60-day 

public comment period at the time that this Proposed Rule is published in the Federal Register. 

To assist the public in commenting on the proposal, EPA has raised a number of issues in the 

preamble to the Proposed Rule and asked for the public to comment on them. At the end of the 

comment period, EPA will review public comments received in response to the notice and will 

address comments received, as appropriate. 

 3(c) Consultations

EPA consulted with U.S. Customs and Border Protection and U.S. Census Bureau on the 

AES filing requirements. EPA did not consult with any other organizations in the development 

of this ICR. 

 3(d) Effects of Less Frequent Collection

EPA has carefully considered the burden imposed upon the regulated community by the 

hazardous waste export-import revisions. 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 cannot ensure that hazardous wastes are properly managed and do 

not pose a serious threat to human health and the environment. 

 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 proposed 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. 
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 3(g) Sensitive Questions

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

associated with the proposed rule. 

4. THE RESPONDENTS AND THE INFORMATION REQUESTED 

 4(a) Respondents and NAICS Codes

The revisions to the hazardous waste export and import requirements under the proposed 

rule affect all recycling and disposal facilities who receive imports of hazardous waste and all 

persons who export or import (or arrange for the export or import) of hazardous waste being 

shipped for either recycling or disposal, SLABs being shipped for reclamation, industrial ethyl 

alcohol being shipped for reclamation, and hazardous recyclable materials being shipped for 

precious metal recovery, and hazardous waste samples of more than 25 kilograms being shipped 

for waste characterization or treatability studies. Potentially affected industries may include, but 

are not limited to the following: 

NAICS Industry Sector 

211 Oil and Gas Extraction

212 Mining (except Oil and Gas) 

213 Support Activities for Mining 

311 Food Manufacturing 

324 Petroleum and Coal Products Manufacturing 

325 Chemical Manufacturing 

326 Plastics and Rubber Products Manufacturing 

327 Nonmetallic Mineral Product Manufacturing 

331 Primary Metal Manufacturing 

332 Fabricated Metal Product Manufacturing 

333 Machinery Manufacturing 

334 Computer and Electronic Product Manufacturing 

335 Electrical Equipment, Appliance, and Component Manufacturing 

336 Transportation Equipment Manufacturing 

339 Miscellaneous Manufacturing 

423 Merchant Wholesalers, Durable Goods 

424 Merchant Wholesalers, Nondurable Goods 

441 Motor Vehicle and Parts Dealers 

482 Rail transportation 

483 Water transportation 

484 Truck transportation 

488 Support Activities for Transportation 
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NAICS Industry Sector 

531 Real Estate 

541 Professional, Scientific, and Technical Services 

561 Administrative and Support Services 

562 Waste Management and Remediation Services 

721 Accommodation 

924 Administration of Environmental Quality Programs 

 This list of potentially affected entities 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. 

 4(b) Information Requested

This section describes the information collection requirements applicable to entities that 

would be affected by the Proposed Hazardous Waste Export-Import Revisions Rule. 

CDX Registration 

(i) Data Items: 

The proposed rule establishes requirements for electronic reporting for exporters and 

importers of hazardous waste. Many of the activities required for these entities will be 

determined by instructions associated with EPA’s electronic document receiving system. Under 

the proposed rule, EPA plans to develop enhancements to the Waste Import Export Tracking 

System (WIETS) to receive these submittals, likely using the Agency-wide CDX system, which 

will facilitate the electronic submittal of required documents. WIETS guides users through the 

registration and reporting procedures. Electronic submittal is required for all exporters and 

importers, with the exception of companies that meet certain conditions specified by EPA. Each 

entity required to submit documents electronically will need to register to use the system. To the 

extent that CROMERR applies, each submittal will require that the exporter or importer provide 

an electronic signature. 

Under the proposed rule, EPA estimates that any staff involved in the reporting of 

export/import notices, annual reports, or other required documents would have to register using 

the electronic receiving system. If identity proofing fails, registrants are routed to an “electronic 

signature agreement” form that is completed on the computer, printed out, signed, and then 

mailed to EPA. In addition, EPA estimates that 10 percent of users will have to update their 

information each year. EPA also estimates that 10 percent of users will have to register as new 

users due to employee turnover and 1 percent of users will have to re-register due to 

compromised signatures each year. 
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(ii) Respondent Activities: 

 All users will need to register using EPA’s electronic receiving system and update their 

information when necessary. EPA estimates that importers will have an average of 4.7 users and 

exporters will have an average of 5 users.6

 If identity proofing fails, the user will need to print 

and complete a document, sign it, and mail it to EPA. 

Notification 

 

(i) Data Items: 

Under the proposed §262.83(b), exporters sending hazardous waste to Canada, Mexico, 

and non-OECD countries will be required to submit additional information with each notice. 

This additional informational includes an e-mail address and fax number for each listed party on 

the notice, all anticipated ports of exit, all anticipated transporters for the shipments, any interim 

facilities to be used during the transfer of waste, and the OECD waste codes and recycling or 

disposal operation codes for all waste streams to be shipped. 

Exporters to Canada will not experience an additional burden from listing transporters 

and interim facilities, as these data elements are already required by Canadian regulations. 

Exporters to other OECD countries are already required to submit this information, and will 

therefore experience no change in their cost burden as a result of the proposed rule. 

Once the electronic system becomes fully operational, exporters will have the option to 

use the duplication feature in WIETS (in which data field information is copied from the 

previous notice), which will reduce this estimated burden for entities that submit identical notices 

(with the exception of the first and last shipment date fields) from year to year. EPA estimates 

that 60 percent of exporters will be able to take advantage of this duplication feature and incur no 

additional burden for providing supplemental information in WIETS starting in the second year 

after electronic submittal is formally mandated. The remaining 40 percent of exporters will have 

to enter this information for each new export notice. 

The proposed rule would require receiving facilities in the U.S. importing waste from 

maquiladoras in Mexico to submit import notices on behalf of these foreign exporters for any 

waste shipments not controlled as hazardous waste exports by Mexican authorities. 

The proposed rule also requires electronic submittal of notices using WIETS. To the 

extent that CROMERR applies, this would require exporters and importers to provide an 

electronic signature with each notice. 

The proposed rule will eliminate the existing §264.12(a)(1) requirement that importers 

notify a regional administrator four weeks prior to receiving a shipment of hazardous waste for 

the first time. This will result in a cost savings for U.S. importers. 

 

6

 EPA estimates that large firms will have 6 employees and small firms will have 3 employees register to use the EPA’s electronic receiving system. 

The estimates of 4.7 and 5 users per entity are based on the distribution of large and small firms among potentially affected importers and 

exporters based on data collected from Dun & Bradstreet (D&B).
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(ii) Respondent Activities: 

Exporters must prepare and submit an export notice 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. If CROMMER applies, they must also electronically sign the notice. 

Importers must prepare and submit a notice on behalf on the foreign exporter for 

shipments from maquiladoras in Mexico that are not controlled as hazardous waste exports by 

the foreign authority. The notice 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, and may cover shipments over a 12-month period. If CROMERR applies, 

importers must also electronically sign the notice. 

One-time notices identifying the name, address, and contact information for a U.S. 

receiving facility and every new waste stream they intend to import are no longer required. 

Re-notification 

(i) Data Items: 

Under the proposed §262.83(b), as under the existing §262.53(c), when the conditions 

specified under the original notification change, the U.S. exporter must provide EPA with a renotification of the change. The proposed rule requires electronic submittal of all re-notifications 

sent to EPA. This will require each exporter to provide an electronic signature for certain data 

elements on each notice submitted. 

Also, under the proposed §262.83(e) and (f) where a single shipment cannot be delivered 

or is rejected for any reason, the transporter or receiving facility must notify the exporter, EPA 

and the country of import or transit of the situation. Then, alternate management must be found 

in the country of import that is acceptable to the country of import, or the shipment must be 

returned to the United States; and finally, the exporter must submit an exception report. 

(ii) Respondent Activities: 

U.S. exporters must prepare and submit a re-notification to EPA if they wish to change 

the terms of the original notice. U.S. exports must submit an exception report if the shipment 

cannot be delivered. To the extent that CROMERR applies, the exporter must sign these 

documents electronically. 
14

Annual Reports 

(i) Data Items: 

Under the proposed §262.83(g), as under the existing §262.87(a), LQG exporters must 

list OECD waste codes for all shipments in addition to RCRA waste codes as part of each annual 

report. The proposed rule will also require electronic submittal of all annual reports of exports of 

hazardous waste and CRTs for recycling. This will require each annual report to be signed 

electronically. 

(ii) Respondent Activities: 

 

 U.S. exporters must enter OECD waste codes into each annual report. Exporters must 

also electronically sign each annual report. 

Additional Reports 

(i) Data Items: 

Under the proposed §262.83(b)(8), as under the existing §262.53(d) and §262.83(d)(14), 

upon request by EPA, an exporter must continue to submit to EPA any additional information 

which a country of import requests in order to respond to a notification. The proposed rule will 

not change this requirement or the manner through which such information is submitted to EPA. 

(ii) Respondent Activities: 

 U.S. exporters must prepare and submit additional information to EPA upon request. This 

is the same as in the baseline. 

 Contracts 

(i) Data Items: 

Under the proposed rule, contracts must be signed between exporters of hazardous waste 

and receiving facilities specifying the parties relevant to each shipment and the various legal 

responsibilities of each party involved. Currently, there are no requirements for contracts in the 

U.S. under 40 CFR Part 262 Subpart E. However, Canadian regulations require that such 

contracts be maintained. EPA therefore assumes that shipments to Canada will not experience 

any additional burden as a result of this provision. EPA assumes that other entities involved in 

the foreign trade of hazardous waste currently sign similar contracts that would satisfy the 

proposed requirements, and therefore estimates no additional incremental burden for these 

shipments. 
15

(ii) Respondent Activities: 

None. 

Acknowledgement of Consent 

(i) Data Items: 

Under the existing §262.52(c) and §266.80(a), exporters are required to provide a copy of 

the EPA Acknowledgment of Consent for each shipment to the transporter transporting the 

shipment for export. The proposed rule eliminates this requirement. Thus, this would result in a 

cost savings for U.S. exporters. 

(ii) Respondent Activities: 

 U.S. exporters no longer need to provide a copy of the EPA Acknowledgment of Consent 

to the transporter. 

Exception Reports 

(i) Data Items: 

Whereas exception reports for Subpart E are currently based on the RCRA manifest, 

under the proposed §262.83(h), exception reports will be based on either RCRA manifests or 

OECD movement documents for shipments to Canada, Mexico and non-OECD countries. The 

proposed rule also requires exception reports to be submitted electronically to EPA. To the 

extent that CROMERR applies, this will require that each exception report be signed 

electronically. 

(ii) Respondent Activities: 

 U.S. exporters must prepare and submit the required exception report if any of the 

conditions listed in §262.83(h) occurs. 

Movement/Tracking Document 

(i) Data Items: 

Under the proposed §262.83(d), each time a U.S. exporter ships hazardous waste to a 

foreign country – including Canada, Mexico, and non-OECD countries – the exporter is required 

to complete and submit to the carrier a movement/tracking document. The movement document 

must include a signed certification, as well as all information required for notification. For 

shipments to and from Canada, exporters may use the existing Canadian movement document to 

fulfill this requirement. U.S. exporters must maintain copies of the movement documents they 

receive from foreign receiving facilities to confirm receipt for three years.
16

Under the proposed rule, U.S. receiving facilities must send a copy of the signed OECD 

movement document to EPA electronically, to the foreign exporter of the waste, and to the 

relevant authorities of the exporting country and any transit countries within three days of 

receiving a shipment of hazardous waste. Importers must also maintain a signed copy of the 

movement document for three years. Importers receiving waste from other OECD countries must 

already comply with this requirement and will experience no increase in cost as a result of this 

provision. Similarly, importers receiving waste from Canada can use the Canadian movement 

document to fulfill this requirement and will experience no additional cost burden to complete 

the document, but will incur costs to send a copy to EPA and Environment Canada. To the extent 

CROMERR applies, U.S. importers must submit copies of the movement document to EPA 

electronically with an electronic signature. 

(ii) Respondent Activities: 

U.S. exporters shipping hazardous waste to Mexico and non-OECD countries must 

complete and submit a movement/tracking document to the carrier, and maintain copies of the 

movement document they receive to confirm receipt from the foreign receiving facility for three 

years. U.S. importers must send a copy of the signed OECD movement document to EPA 

electronically, to the foreign exporter of the waste, and to the relevant authorities of the 

exporting country within three days of receiving a shipment of hazardous waste. To the extent 

CROMERR applies, electronic submittal of the copies must be done with an electronic signature. 

U.S. importers from Mexico and non-OECD countries must also maintain a signed copy of the 

movement document for three years. 

Confirmation of Recovery or Disposal 

(i) Data Items: 

Under the existing §262.83(e), all U.S. recovery facilities must provide a confirmation of 

recovery or disposal to the exporter and send copies to the competent authorities of the countries 

of export and import. The confirmation 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. U.S. importers receiving shipments from Canada are already required to prepare 

and send a confirmation of recovery or disposal to the foreign exporter under Canadian 

regulations, and therefore only incur costs to send copies of this document to EPA and 

Environment Canada. Furthermore, under the proposed §262.83(f)(5) EPA will require export 

contract terms that specify foreign receiving facilities sending confirmations of 

recycling/disposal that will allow use of the Canadian confirmation of recycling or disposal, and 

under the proposed §262.84(g) U.S. importers will be required to provide a confirmation of 

recovery/disposal and will be able to use the Canadian confirmation of recycling/disposal to use 

one document to list multiple shipments identified by their movement document number, waste 

line number, and the date of recycling or disposal. The proposed rule will require that U.S. 

importers submit copies of the confirmation of recovery or disposal to EPA electronically, and to 

the extent CROMERR applies, will need to include an electronic signature. 
17

U.S. exporters must also maintain a copy of the confirmation of recovery/disposal from 

the foreign importing facility for three years. U.S. importers will also need to maintain a copy of 

the confirmation of recovery/disposal for three years. While exporters and importers exchanging 

waste with OECD countries other than Canada and Mexico are already subject to this 

requirement under existing regulations, exporters and importers involved in the foreign trade of 

hazardous waste with Mexico, Canada, and non-OECD countries will experience an increase in 

cost burden as a result of these additional recordkeeping requirements. 

(ii) Respondent Activities: 

U.S. importers must provide a confirmation of recovery to the exporter, EPA, and the 

competent authority of the country of export. Copies must be submitted to EPA electronically, 

and to the extent CROMERR applies, will need to include an electronic signature. U.S. exporters 

must receive and maintain the confirmation of recovery/disposal provided by the recovery 

facility for three years, and U.S. importers must maintain a copy of the confirmation of 

recovery/disposal for three years. 

Return of Wastes 

(i) Data Items: 

Under the existing §262.54(g), when a manifested shipment of hazardous waste cannot be 

completed, the primary exporter must (1) instruct the transporter to either return the shipment to 

the exporter or to an alternative facility in the United States, and (2) submit an exception report 

to EPA. The proposed rule does not change any of these requirements with the exception of 

allowing the alternate facility to be in the country of import if allowed by the country of import, 

specifying that the instructions to the transporter be made via mail, e-mail, or fax (so that a 

record of the instructions exists), and requiring that the shipments be returned within 90 days of 

receiving notification from the country of import or transit. 

(ii) Respondent Activities: 

 U.S. exporters must instruct the transporter to either return the shipment to the exporter or 

to an alternative facility in the country of import (if allowed by the country of import) or the 

United States. 

Exemption of Wastes Destined for Laboratory Analysis 

(i) Data Items: 

Under the existing §262.82(g), import and export shipments of RCRA hazardous wastes 

with OECD countries other than Canada and Mexico are exempt from the Subpart H 

requirements if they are explicitly destined for laboratory analysis to assess their 

physical/chemical characteristics or to determine their suitability for recovery operations and no 

more than 25kg. Under existing regulations in 40 CFR Part 261, domestic shipments of 
18

hazardous waste sent for laboratory analysis are exempt from hazardous waste requirements if 

they fall within certain weight limits. Existing weight limits for exempted waste shipments range 

from 1kg for acute hazardous waste to 10,000kg of media contaminated with non-acute 

hazardous waste. The proposed rule makes exporters and importers shipping samples for 

laboratory analysis to and from Canada, Mexico, and non-OECD countries subject to the 

additional limitation of samples weighing no more than 25kg to be exempt from export and 

import requirements. As a result, currently-exempt shipments may no longer be exempt. EPA 

estimates that four previously-exempted shipments (two export shipments and two import 

shipments) will no longer be exempted each year after the implementation of the proposed rule. 

EPA is requesting comment on the number of currently exempt shipments that will be impacted 

by this change. 

(ii) Respondent Activities: 

U.S. exporters shipping samples less than the domestic limits in 40 CFR Part 261 but 

greater than 25kg for laboratory analysis to Canada, Mexico, or a non-OECD country will now 

need to comply with the subpart H requirements, including submitting an export notice, 

obtaining an AOC, filing the additional items in AES to validate consent for the sample 

shipment, completing and signing a movement/tracking document, and receiving and 

maintaining a confirmation of recovery. Transporters of these samples will need to comply with 

hazardous waste manifest and movement document requirements to obtain, sign, and maintain a 

copy of the RCRA manifest and obtain and sign the movement/tracking document. U.S. 

importers receiving samples less than the domestic limits in 40 CFR Part 261 but greater than 

25kg for laboratory analysis from Canada, Mexico, or a non-OECD country will now need to 

comply with the subpart H requirements, including signing the RCRA manifest and submitting 

the RCRA manifest to EPA, signing the movement/tracking document and providing a copy to 

the exporter, EPA, and competent authority of the country of export to confirm receipt, and 

sending a confirmation of recovery to the exporter, EPA, and foreign authority. 

EPA ID 

(i) Data Items: 

The proposed rule will require all recognized traders involved in the arrangement of 

transportation of hazardous waste to obtain an EPA ID number. EPA assumes that one percent of 

all importers and exporters are recognized traders, or about four entities, and will be impacted by 

the proposed rule. EPA also assumes the number of recognized traders is split equally among 

exporters and importers. 

(ii) Respondent Activities: 

 Recognized traders of hazardous waste must obtain an EPA ID number from their 

authorized state or from EPA. 
19

AES Requirements 

(i) Data Items: 

Under the proposed rule in subpart H, exporters will be required to fill in between two 

and five additional fields to validate consent as part of their existing filing in CBP’s AES. The 

proposed rule would also add the same filing requirements for CRTs exported for recycling 

under 40 CFR 261.39. 

(ii) Respondent Activities: 

 Exporters of CRTs for recycling and hazardous waste for recycling or disposal must file 

between two and five additional fields to validate consent as part of their existing AES filing. 

5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

 5(a) Agency Activities

WIETS Development 

To implement the proposed rule, the most significant cost for EPA will be the 

development and maintenance of the electronic submittal system. These costs are uncertain; 

therefore this ICR presents Agency costs as a range. Any costs of the CDX system are not 

described in this ICR because it exists now, would still exist absent the rule, and was developed 

to facilitate electronic submittal of data between EPA data systems and other entities such as the 

regulated community and other governments. However, EPA estimates that the initial 

development of enhancements to WIETS to facilitate electronic submittal of export and import 

reports (specifically related to the propose rule) will cost between $188,750 and $311,250.7

 EPA 

also estimates that it will require between approximately 700 and 1,170 labor hours for staff 

technicians to implement the system at a cost ranging from $39,076 to $65,127.8

 This ICR 

assumes that the development costs are entirely incurred in the first year of the rule’s 

promulgation and the system will have a useful lifespan of 20 years. EPA further estimates that 

the recurring O&M costs for the enhancements to WIETS will be between $96,750 and $161,250 

per year after its development. Finally, EPA estimates that it will require between approximately 

1,500 and 2,500 hours to manage the enhancements to WIETS after their implementation at a 

cost ranging from $83,015 to $138,359 per year. 

Since the electronic submittal system will provide technical guidance and tracking 

information to users, EPA estimates it will no longer have to respond to exporter inquiries related 

to the submittal of export notices. EPA estimates that such inquiries require 1,000 hours of 

 

7

 EPA cost estimates for the development and operation & maintenance of the electronic system are derived from the Excel Workbook “EPA FTEs 

and Costs for import-export rule RANGES Jan 8 2015.docx” provided by Phuc Phan of EPA’s Office of Resource Conservation and Recovery on 

January 15, 2015. 

8

 EPA labor costs are estimated using the loaded hourly labor rates described in Chapter 3 of the Economic Assessment for the proposed rule. 
20

Agency staff time each year. Furthermore, electronic submittal will reduce the Agency burden 

associated with manual entry of export notices. EPA receives approximately 1,684 notices per 

year and requires one hour to manually enter information from each export notice into WIETS. 

Therefore, Agency staff will experience a cost savings of 1,000 hours per year for avoided 

inquiries and 1,684 hours per year for avoided data entry. EPA also estimates that electronic 

submittal will eliminate the need for staff to manually enter information from export annual 

reports into WIETS. EPA receives approximately 378 export annual reports each year and takes 

about four hours to receive and process reports into a database. Therefore, EPA estimates that 

Agency staff will also experience a cost savings of 1,512 hours for avoided data entry associated 

with export annual reports. 

Movement/Tracking Document 

Under the proposed §262.83 and §262.84, exporters and importers that trade with 

Canada, Mexico, and non-OECD countries will have to comply with movement document 

requirements. As discussed above, exporters and importers that trade with other OECD countries 

are already required to submit signed movement documents to EPA. EPA will need to receive 

and record movement documents from importing countries for U.S. exports and receiving 

facilities for U.S. imports. 

Confirmation of Recovery or Disposal 

EPA will need to review and maintain a confirmation of recovery or disposal for 

hazardous waste shipments between the United States and Canada, Mexico, and non-OECD 

countries. 

EPA ID 

For recognized traders not located in authorized states that issue EPA ID numbers, EPA 

will need to review letters from recognized traders of hazardous waste requesting EPA 

identification numbers, enter this information into a database, generate an EPA ID number, and 

send it to each requesting recognized trader. 

 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 

Some respondents will be small organizations. In certain cases, they will be able to obtain 

waivers to avoid reporting requirements associated with electronic submission of documents to 

EPA. Small entities may also incur fewer costs because they can complete the recordkeeping and 

reporting requirements in less time than large organizations because they export or import 
21

smaller quantities of hazardous waste. However, the size of the organization does not always 

reflect the amount of time needed to complete documents, submit reports, or maintain records. 

EPA believes that the information to be collected is the minimum amount necessary to fulfill the 

purpose of the proposed rule. Furthermore, the decision to export or import hazardous waste is 

voluntary. 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. 

 5(d) Collection Schedule

Under the proposed rule, export/import notifications, exception reports, documentation of 

EPA’s consent to import, confirmations of recovery/disposal, and shipment tracking documents 

are generated and sent to EPA on an occurrence-specific basis for which there is no formalized 

schedule. The submission of information under this collection is initiated by the respondents. 

U.S. exporters must file with EPA a detailed annual report on hazardous waste 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 

EPA assessed the potential cost impacts of the proposed rule, including: 

 Submittal of notices to EPA on behalf of foreign exporters by U.S. importers (for 

RCRA hazardous wastes not controlled as hazardous waste exports by the country 

of export). 

 Submittal of additional information with each export notice. 

 Listing of OECD waste codes for all shipments in each export annual report of 

hazardous wastes. 

 Development of contracts between U.S. exporters of hazardous waste and foreign 

receiving facilities, and between U.S. importers of hazardous waste and foreign 

exporters. 

 Removal of the requirement for exporters to provide a copy of EPA’s 

Acknowledgment of Consent to transporters for each shipment. 

 Movement document creation for exporters of hazardous waste. 

 Transporters signing movement documents for import and export shipments. 

 U.S. receiving facilities’ signing and distribution of the OECD movement 

document to EPA, the generator of the waste, and the relevant authorities of the 

exporting country. 

 U.S. receiving facilities’ preparation and shipment of the confirmation of recovery 

or disposal to EPA, the exporter, and the relevant authority in the country of 

origin for each shipment received. 

 U.S. exporters’ maintenance of a copy of the confirmation of recovery or disposal 

from the foreign importing facility. 
22

 The return of hazardous waste shipments to U.S. exporting facilities or alternate 

facilities in the country of import (if allowed by the country of import) or the 

United States. 

 The exemption of various wastes destined for laboratory analysis from hazardous 

waste requirements when shipments contain no more than 25kg. 

 The obtaining of EPA identification numbers by recognized traders of hazardous 

waste. 

 Requirements for exporters of hazardous waste for recycling/disposal and CRTs 

for recycling to enter new data elements into the existing AES. 

 CDX registration. 

6(b) Estimating Respondent Costs

Labor Costs

For purposes of this analysis, this ICR estimates an average hourly respondent labor cost 

(including fringe benefits and overhead costs) of $139.53 for managerial staff, $67.40 for 

technical staff, and $36.05 for clerical staff. These hourly labor costs were obtained from the 

following source: 

 Hourly Wage: Bureau of Labor Statistics, occupational earnings data for May 

2013.9,10

 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.” 

 O&M costs are those costs associated with materials and services procured for the 

information collection requirements included in this ICR. For this ICR, O&M costs include the 

following: (1) postage to mail a five-ounce package by certified mail ($2.09 for postage, $3.30 

for the certified-mail fee, and $0.16 for a 9 x 12 manila envelope = $5.55); (2) postage to mail a 

standard domestic letter ($0.49 for first class postage and $0.03 for a standard envelope = $0.52); 

(3) postage for a standard international letter ($1.15 for first-class postage and $0.03 for a 

standard envelope = $1.18); (4) photocopying ($0.11 per page); and (5) fax services ($0.12 per 

page). 

 

 6(c) Estimating Agency Burden and Costs 

 

9

 Bureau of Labor Statistics, National Occupational Employment and Wage Estimates, May 2013, accessed at 

http://www.bls.gov/oes/current/oes_nat.htm on April 24, 2014. 

10 To estimate average annual labor costs, EPA relies on national average wage data reported by the U.S. Bureau of Labor Statistics for a full time 

employee working 40 hours a week multiplied by a loaded wage rate of 150 percent, which represents average private industry fringe benefits 

(e.g. paid time off, health benefits, retirement benefits, other legally required benefits, and payroll taxes) and overhead rates (e.g. general and 

administrative, fixed overhead, insurance, and profit). 
23

For Agency burden and costs, EPA estimates an average hourly labor rate of $65.58 for 

managerial staff (GS-14, Step 1), $55.50 for technical staff (GS-13, Step 1), and $21.25 for 

clerical staff (GS-5, Step 1).11 To derive these hourly estimates, EPA referred to the General 

Schedule (GS) Salary Table 2014. 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 proposed 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: “Assessment of the 

Potential Costs, Benefits, and Other Impacts of the Hazardous Waste Export-Import Revisions 

Rule” (hereinafter referred to as the Cost Assessment document for the proposed rule), which is 

available in the docket for the rule. 

(1) Respondent Universe

In Exhibits 1 and 2 below, EPA provides estimates of the annual number of importers and 

exporters (and export and import shipments) that will be subject to the paperwork requirements 

in the proposed rule. 

 

11 See Chapter 3 of the Economic Assessment for the proposed rule.
24

Exhibit 1 

Number of Importers and Shipments Potentially Affected by the Proposed Rule

Country of Origin1 Number of Affected Entities Average Number of 

Shipments per Year7,8 U.S. Importers U.S. Transporters6

Canada2,3,4,5 35 35 69 

Mexico2,3,5 11 11 31 

OECD Countries 2 2 31 

Non-OECD Countries 3 3 37 

Total 51 51 57 

Notes: 

1. Four importers received waste from two or more countries. Therefore, there are 45 unique 

importers, rather than 51 listed above. However, this exhibit parses out the importers that 

receive from more than one country into each of their respective origins to accurately 

reflect the average number of shipments sent to each importer. Depending on the context, 

the remainder of this analysis may similarly parse out importers that receive from more 

than one country separately to accurately estimate costs associated with receiving from 

alternative destinations. That is, this assessment often uses the 51 count of importers and 

not the 45 unique importers. 

2. While Canada and Mexico are OECD countries, under existing regulations there are 

different requirements for the foreign trade of hazardous waste with these countries 

compared with other OECD countries. Therefore, EPA estimates impacts to importers 

(and exporters) separately for trade with Canada and Mexico versus other OECD 

countries. 

3. Two importers received shipments from Canada and Mexico. 

4. A single importer received shipments from England, Germany, and Canada. 

5. A single importer received shipments from Malaysia, the Philippines, Canada, Mexico, 

and Japan. 

6. EPA estimates that there is one U.S. transporter for each U.S. importer. 

7. Average number of shipments based on EPA RCRA manifests for import shipments for 

2011. This is not an average of the number of affected entities columns. 

8. EPA estimates that two imported shipments per year are destined for laboratory analysis. 
25

Exhibit 2 

Number of Exporters and Shipments Potentially Affected by the Proposed Rule

Destination Country1

Number of Affected Entities Average Number of 

Shipments per Year5,6 U.S. Exporters U.S. 

Transporters4

Canada2,3 326 326 79 

Mexico2,3 24 24 964 

OECD Countries 31 31 80 

Non-OECD Countries 2 2 13 

Total 383 383 134 

Notes: 

1. Four exporters shipped waste to two or more countries. Therefore, there are 378 unique 

exporters, rather than 383 listed above. However, this exhibit parses out the exporters that 

ship to more than one country into each of their respective destinations to accurately reflect 

the average number of shipments sent to each destination. Depending on the context, the 

remainder of this analysis may similarly parse out exporters that ship to more than one 

country separately to accurately estimate costs associated with shipping to alternative 

destinations. In other words, this RIA sometimes uses the 383 count of exporters and not 

the 378 unique exporters where appropriate. 

2. While Canada and Mexico are OECD countries, under existing regulations there are 

different requirements for the foreign trade of hazardous waste with these countries 

compared with other OECD countries. Therefore, EPA estimates impacts to exporters (and 

importers) separately for trade with Canada and Mexico versus other OECD countries. 

3. One exporter sent shipments to both Canada and Mexico. 

4. EPA estimates that there is one U.S. transporter for each U.S. exporter. 

5. Average number of shipments based on EPA Export Annual Reports for 2011. This is not 

an average of the number of affected entities columns. 

6. EPA estimates that two exported shipments per year are destined for laboratory analysis.

(2) Annual Respondent Hour and Cost Burden under the Proposed rule 

Annual respondent hour and cost burden estimates are summarized below and itemized in 

the exhibits at the end of this document. 

(a) Reading the Regulations

EPA expects that all 378 exporters and 45 importers will need to familiarize themselves 

with the requirements of the proposed rule.12 EPA assumes that reading and understanding the 

proposed rule will require one hour of a manager’s time and 2.5 hours of a technician’s time.13 

This is equivalent to an upfront cost of $308.03 per facility. 

 

12 For reporting purposes, EPA estimates that if an exporter ships waste to both Canada and Mexico, half of the costs are incurred for shipments to 

Canada and half are incurred for shipments to Mexico. Therefore, costs are proportionally distributed (by country) for entities that trade with 

more than one country. 

13 Page B-1 of the Cost Assessment for the Proposed 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: Office of Resource Conservation and Recovery, Office of 

Solid Waste and Emergency Response, U.S. Environmental Protection Agency, May 2009. 
26

(b) CDX Registration 

EPA assumes that exporters and importers will register to use the CDX system starting in 

the first year of the rule’s promulgation. The average initial registration cost per entity is 

estimated to be $56.91 per exporter (assuming an average of 5 registrants per exporter) and 

$53.50 per importer (assuming an average of 4.7 registrants per importer), including the cost of 

printing, signing, and mailing an “electronic signature agreement” to EPA if the registrant fails 

the system’s identity-proofing requirements. The estimated recurring costs following the 

promulgation of the rule are $6.94 per exporter and $6.52 per importer, including the cost to 

register new users due to employee turnover and allow existing users to update their information 

each year. 

(c) Export and Import Notices 

Notification cost burdens will vary under the proposed rule for exports to Canada, 

Mexico, non-OECD countries, and OECD countries. During the first year of the proposed rule, 

additional data entry costs per U.S. exporter will be as follows: $56.73 (Canada); $48.04 

(Mexico); and $33.70 (non-OECD). In each subsequent year, U.S. exporters will experience the 

following average costs: $22.69 (Canada), $19.22 (Mexico), and $13.48 (non-OECD). U.S. 

exporters to all countries will incur a cost burden of $0.56 to electronically sign each notice 

submitted electronically. U.S. importers receiving shipments from Mexico will face incremental 

notification costs of $1,317.98 per notice in the first year, and $534.54 in each subsequent year. 

The removal of the one-time notification requirement in the proposed rule will also result 

in cost savings of $37.48 for each affected U.S. importer. In addition, the electronic submittal of 

import manifests to EPA will result in materials-related cost savings of $0.74 per shipment for all 

U.S. importers. 

(d) Re-notification 

Under the proposed rule, EPA estimates that 32 percent of export notices per year 

(approximately 290 in total) will require re-notification each year. The average costs per exporter 

for this activity are as follows: $0.46 (Canada); $0.26 (Mexico); $0.18 (OECD); and $0.29 (nonOECD). Electronic submittal of re-notifications will result in materials-related cost savings for 

U.S. importers of $0.52 for each submission. 

(e) Annual Reports 

Annual reporting requirements under the proposed rule are estimated to result in annual 

costs per exporter of $0.56 per submission (one per year) to provide an electronic signature. In 

addition, the electronic submittal of annual reports will result in materials-related cost savings of 

$5.55 per notice for all U.S. exporters. 
27

(f) Additional Reports 

EPA estimates no change in exporter burden related to requirements for additional 

reports. 

(g) Contracts 

EPA assumes that other entities involved in the foreign trade of hazardous waste 

currently sign similar contracts that would satisfy the proposed requirements, and therefore 

estimates no additional incremental burden for these shipments. 

(h) Acknowledgment of Consent to Transporter 

The proposed rule eliminates the requirement that exporters provide a copy of the EPA 

Acknowledgment of Consent to transporters. This generates the following per-entity savings for 

exporters: $725.01 (Canada); $8,896.28 (Mexico); and $120.02 (non-OECD).

(i) Exception Reports 

This component of the proposed rule will burden exporters with the incremental 

requirement of an electronic signature for each submission, leading to a cost burden of $0.56 per 

affected exporter. Electronic submission of exception reports will also save U.S. exporters $0.52 

in materials-related costs for each report submitted to EPA. 

(j) International Movement/Tracking Document 

U.S. exporters to Mexico and non-OECD countries are estimated to incur incremental 

reporting costs of $52.28 per shipment, for a total per-entity cost of: $50,371.32 (Mexico) and 

$679.58 (non-OECD). U.S. imports from Canada, Mexico, and non-OECD countries will also 

face an incremental reporting burden, estimated on a per-entity basis to be: $120.17 (Canada), 

$2,251.39 (Mexico) and $2,671.47 (non-OECD). Electronic submission of the movement 

document by U.S. importers from OECD countries will result in materials-related cost savings of 

$0.52 per submission. 

(k) Confirmation of Recovery or Disposal 

U.S. exporters to Canada, Mexico, and non-OECD countries are estimated to incur 

incremental costs per shipment under this requirement, yielding a per entity cost of: $283.09 

(Canada); $3,473.72 (Mexico); and $46.87 (non-OECD). 

U.S. importers from Canada, Mexico, and non-OECD countries will also face an 

incremental reporting burden to send a confirmation of recovery or disposal to the exporter, 

EPA, and competent authority of the country of export. The average cost burden per entity is 

estimated as follows: $1,752.88 (Canada); $791.16 (Mexico); and $938.78 (non-OECD). All 

importers will experience an additional cost of $0.56 to electronically sign each confirmation of 

recovery or disposal. 
28

(l) Return of Wastes 

EPA does not estimate any incremental burden resulting from changes to this provision. 

(m) Exemption of Wastes Destined for Laboratory Analysis 

EPA estimates that each shipment no longer qualifying for this exemption will cost 

exporters $55.33, importers $94.90, and transporters $4.95. Exporters will also experience $9.01 

in cost savings per shipment that is no longer exempt. A total of two import shipments and two 

export shipments per year are expected to no longer be exempt across all shipments to and from 

Canada, Mexico, and non-OECD countries. 

(n) Automated Export System Filing Requirements 

No change in burden is estimated relating to this provision. 

(o) Obtain EPA Identification Numbers 

Obtaining an EPA identification number is estimated to cost $37.48 for each recognized 

trader of hazardous waste. 

 6(e) Bottom Line Burden Hours and Costs

(1) Respondent Tally

Exhibit 22 reports the number of respondents that must comply with information 

collection activities under the proposed rule. Exhibit 23 reports the total annual respondent 

burden and costs associated with the aforementioned new information collection activities. The 

exhibit shows that the total annual respondent burden under the proposed rule during the first 

year of its implementation, including the cost of reading the rule, is estimated to be 44,701 hours 

and $1,249,747. In each subsequent year, the respondent burden is estimated to be 42,467 hours 

and $1,067,834. In each year, cost savings associated with the proposed rule are estimated to be 

$454,752.56 across all respondents. For the affected hazardous waste generator entities, the 

average number of responses per affected entity is estimated to be 7.8 in the first year after the 

promulgation of the rule and 5.3 per year in each subsequent year. Thus, the average number of 

responses per entity in the first three years of the rule is 6.1 per year. Finally, Exhibit 24 reports 

the average annual private industry and Agency burden and cost estimates for the first three 

years of the rule. 

 Respondents Hours O&M Cost Total Cost 

Year 1 1,305 44,701 $1,249,747 

After Year 1 42,467 $1,067,834 

Annual Total 1,305 43,212 $0 $1,128,472 

(2) Agency Tally
29

The estimated annual cost to the Agency is $908,708. 

 Total Cost 

Year 1 (High End) $959,968.66 

After Year 1 (High End) $883,078.20 

Annual Average Total (High End) $908,708.35 

Estimated Agency costs and cost savings for the various information collection activities 

under the proposed rule, as delineated in Section 5(a) above, are presented in Exhibits 20 and 21 

below. The exhibits show that the total annual Agency burden under the proposed rule is 

estimated to include between $188,750 and $311,250 in development costs for enhancements to 

WIETS, between $39,076 and $65,127 in development-related labor costs, between $96,750 and 

$161,250 in annual operations and maintenance costs, and between $83,015 and $138,359 in 

labor costs required for operation and maintenance activities. EPA will also incur additional 

costs for processing movement documents, confirmations of recovery, and requests for EPA IDs 

from recognized traders. These costs are estimated to be $583,592 in the first year of the rule, 

and $583,469 in each subsequent year. EPA is also expected to experience a cost savings of 

$232,895 each year since the electronic system will eliminate the need to manually enter export 

notice and export annual report data and answer exporter inquiries via phone. 

 6(f) Reasons for Change in Burden 

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

necessary to make existing export and import related requirements more consistent with the 

current import-export requirements required for shipments between OECD member countries; 

enable electronic submittal of all export and import-related documents; and enable electronic 

submittal and validation of consent in the AES for export shipments subject to RCRA export 

consent requirements prior to exit. 
30

6(g) Burden Statement 

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average about 5 hours per response. 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.

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA–HQ–RCRA–2015–0147, which is available for online viewing at 

www.regulations.gov, or in person viewing at the RCRA Docket in the EPA Docket Center 

(EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The EPA 

Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through 

Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-

1744, and the telephone number for the RCRA Docket is (202) 566-0270. An electronic version 

of the public docket is available at www.regulations.gov. This site can be used to submit or view 

public comments, access the index listing of the contents of the public docket, and to access 

those documents in the public docket that are available electronically. When in the system, select 

“search,” then key in the Docket ID Number identified above. Also, you can send comments to 

the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th 

Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA 

Docket ID Number EPA–HQ–RCRA–2015–0147 and OMB Control Number 2050-NEW in any 

correspondence.
31

Exhibit 3 

Reading the Rule

(In the first year of Rule Implementation Only) 

Information 

Collection Activity 

Hours and Costs Per Entity Total Hours and 

Managerial 

($139.53/hr) 

Technical 

($67.40/hr) 

Clerical 

($36.05/hr) 

Total 

Hours 

Labor 

Cost 

O&M 

Cost 

Total 

Cost1

Number of 

Respondents2

Total 

Hours 

U.S. Exporters 

Reading the rule 1 2.5 0 3.5 $308.03 $0.00 $308.03 378 1,323 

U.S. Importers

Reading the rule 1 2.5 0 3.5 $308.03 $0.00 $308.03 45 157 

TOTAL - YEAR 1 423 1,480 

Sources: 

(1) Cost Assessment for the Final Rule on Exports and Imports of Hazardous Waste Destined for Recovery Among OECD Countries, Exports 

Lead-Acid Batteries from the U.S., and Import Consent Documentation: Office of Resource Conservation and Recovery, Office of Solid WasEmergency Response, U.S. Environmental Protection Agency, May 2009. (2) Unique entity counts are based on U.S. EPA Export and Import Annual Reports, 2011. 
32

Exhibit 4 

CDX Registration Costs 

Information Collection Activity 

Hours and Costs Per Registrant 

Managerial 

($139.53/hr) 

Technical 

($67.40/hr) 

Clerical 

($36.05/hr) 

Total 

Hours 

Labor 

Cost 

O&M 

Cost 

Total 

Cost 

Number of 

Respondents 

U.S. Exporters 

Initial registration - Year 1 0 0.15 0 0.15 $10.11 $0.00 $10.11 378 New registrations - every year After Year 1 0 0.15 0 0.15 $10.11 $0.00 $10.11 378 Update information - every year After Year 1 0 0.02 0 0.02 $1.35 $0.00 $1.35 378 Electronic signature if registrant fails identity (proofing requirements) - Year 1 

0 0.0833 0 0.0833 $5.61 $0.63 $6.24 378 

Electronic signature if registrant fails identity-proofing requirements - After Year 1 

0 0.0833 0 0.0833 $5.61 $0.63 $6.24 378 

U.S. Importers

Initial registration - Year 1 0 0.15 0 0.15 $10.11 $0.00 $10.11 45 New registrations - every year After Year 1 0 0.15 0 0.15 $10.11 $0.00 $10.11 45 Update information - every year After Year 1 0 0.02 0 0.02 $1.35 $0.00 $1.35 45 Electronic signature if registrant fails identity (proofing requirements) - Year 1 

0 0.0833 0 0.0833 $5.61 $0.63 $6.24 45 

Electronic signature if registrant fails identity-proofing requirements - After Year 1 

0 0.0833 0 0.0833 $5.61 $0.63 $6.24 45 

TOTAL - YEAR 1 423 

TOTAL - AFTER YEAR 1 423 

Source: 

(1) EPA estimates that there are 4.7 registrants per respondent for importers and 5 registrants for exporters. 
33

Exhibit 5 

Notification Costs 

Information Collection Activity 

Hours and Costs Per Notification 

Managerial 

($139.53/hr) 

Technical 

($67.40/hr) 

Clerical 

($36.05/hr) 

Total 

Hours 

Labor 

Cost1,3

O&M 

Cost 

Total 

Cost 

Number 

of Resp.2

U.S. Exporters - Canada 

Submit additional data fields as part of notice of intent to export - Year 1 0 0.33 0 0.33 $22.24 $0.00 $22.24 326 Submit additional data fields as part of notice of intent to export - After Year 1 0 0.132 0 0.132 $8.90 0 $8.90 326 Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 326 

U.S. Exporters – Mexico

Submit additional data fields as part of notice of intent to export - Year 1 0 0.5 0 0.5 $33.70 $0.00 $33.70 24 Submit additional data fields as part of notice of intent to export - After Year 1 0 0.2 0 0.2 $13.48 0 $13.48 24 Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 24 

U.S. Exporters - non-OECD

Submit additional data fields as part of notice of intent to export - Year 1 0 0.5 0 0.5 $33.70 $0.00 $33.70 2 Submit additional data fields as part of notice of intent to export - After Year 1 0 0.2 0 0.2 $13.48 0 $13.48 2 Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 2 

U.S. Exporters – OECD

Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 31 

U.S. Exporters - Other4

Submit additional data fields as part of notice of intent to export - Year 1 0 varies 0 0 varies $0.00 varies 298 Submit additional data fields as part of notice of intent to export - After Year 1 0 varies 0 0 varies $0.00 varies 298 Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 298 

U.S. Importers - Mexico

Submit export notices on behalf of foreign exporters - Year 1 0.1 1.8 0.1 2 $138.88 $6.10 $144.98 11 Submit export notices on behalf of foreign exporters - After Year 1 0.04 0.732 0.04 0.812 $56.36 $2.44 $58.80 11 
34

Information Collection Activity 

Hours and Costs Per Notification 

Managerial 

($139.53/hr) 

Technical 

($67.40/hr) 

Clerical 

($36.05/hr) 

Total 

Hours 

Labor 

Cost1,3

O&M 

Cost 

Total 

Cost 

Number 

of Resp.2

Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 11 

TOTAL - YEAR 1 692 

TOTAL - AFTER YEAR 1 692 

Sources: (1) Cost of import notice from: Supporting Statement for EPA Information Collection Request Number 0820.11 Hazardous Waste Generator 

2011. 

(2) Import notice totals from EPA's International Compliance Assurance Division (ICAD), sent via e-mail from Phuc Phan on June 5, 2014. 

(3) Electronic signature burden from: Supporting Statement for EPA Information Collection Request Number 2002.05: "Cross-Media Electro

Office of Environmental Information, U.S. Environmental Protection Agency. 

(4) This category includes exporters that submit export notices to EPA but do not subsequently export hazardous wastes during the 12-month 

respondents based on 2013U.S. EPA WIETS data. 
35

Exhibit 6 

Notification Cost Savings 

Information Collection Activity 

Hours and Costs Per Notification 

Managerial 

($139.53/hr) 

Technical 

($67.40/hr) 

Clerical 

($36.05/hr) 

Total 

Hours1

Labor 

Cost 

O&M 

Cost3

Total 

Cost 

Savings 

Number 

Responde

U.S. Importers - Canada

One-time notice to regional administrator stating intent to import 0.08 0.34 0.08 0.5 $36.96 $0.52 $37.48 35 Send copy of import manifest to EPA 0.00 0.00 0.00 0 $0.00 $0.74 $0.74 35 

U.S. Importers - Mexico

One-time notice to regional administrator stating intent to import 0.08 0.34 0.08 0.5 $36.96 $0.52 $37.48 11 Send copy of import manifest to EPA 0.00 0.00 0.00 0 $0.00 $0.74 $0.74 11 

U.S. Importers - non-OECD

One-time notice to regional administrator stating intent to import 0.08 0.34 0.08 0.5 $36.96 $0.52 $37.48 3 Send copy of import manifest to EPA 0.00 0.00 0.00 0 $0.00 $0.74 $0.74 3 

U.S. Importers - OECD

One-time notice to regional administrator stating intent to import 0.08 0.34 0.08 0.5 $36.96 $0.52 $37.48 2 Send copy of import manifest to EPA 0.00 0.00 0.00 0 $0.00 $0.74 $0.74 2 

TOTAL 51 

Source: (1) Burden estimate based on burden to obtain a new EPA ID number (similar data submittal process), as taken from: Supporting Statement foNumber 0976.16, "2013 Hazardous Waste Report, Notification of Regulated Waste Activity, and Part A Hazardous Waste Permit Application (2) One-time notices estimated to account for 5 percent of annual import notices. Based on information received from the EPA Regional OfficOffice of Resource Conservation and Recovery. (3) Includes cost for mailing one standard envelope. 
36

Exhibit 7 

Re-notification Costs 

Information Collection 

Activity 

Hours and Costs Per Re-notification To

Managerial 

($139.53/hr) 

Technical 

($67.40/hr) 

Clerical 

($36.05/hr) 

Total 

Hours 

Labor 

Cost 

O&M 

Cost 

Total 

Cost2

Number of 

Respondents 

R

U.S. Exporters - Canada 

Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 326 

U.S. Exporters - Mexico 

Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 24 

U.S. Exporters - non-OECD 

Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 2 

U.S. Exporters - OECD

Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 31 

TOTAL 383 

Source: 

(1) 32 percent of respondents are estimated to submit re-notifications annually. Based on data from EPA's International Compliance Assuranc

(ICAD) sent via e-mail from Phuc Phan on June 5, 2014. (2) Supporting Statement for EPA Information Collection Request Number 2002.05: "Cross-Media Electronic Reporting Rule", June 22, 201

Information, U.S. Environmental Protection Agency. 
37

Exhibit 8 

Re-notification Cost Savings 

Information Collection 

Activity 

Hours and Costs Per Re-notification T

Managerial 

($139.53/hr) 

Technical 

($67.40/hr) 

Clerical 

($36.05/hr) 

Total 

Hours 

Labor 

Cost 

O&M 

Cost 

Total 

Cost2

Number of 

Respondents 

U.S. Exporters - Canada 

Submit re-notification to EPA 0 0 0 0 $0.00 $0.52 $0.52 326 

U.S. Exporters - Mexico 

Submit re-notification to EPA 0 0 0 0 $0.00 $0.52 $0.52 24 

U.S. Exporters - non-OECD 

Submit re-notification to EPA 0 0 0 0 $0.00 $0.52 $0.52 2 

U.S. Exporters - OECD

Submit re-notification to EPA 0 0 0 0 $0.00 $0.52 $0.52 31 

TOTAL 383 

Source: 

(1) 32 percent of respondents are estimated to submit re-notifications annually. Based on data from EPA's International Compliance Assuranc

(ICAD) sent via e-mail from Phun Phan on June 5, 2014 (2) Supporting Statement for EPA Information Collection Request Number 2002.05: "Cross-Media Electronic Reporting Rule", June 22, 201

Information, U.S. Environmental Protection Agency 
38

Exhibit 9 

Annual Report Costs 

Information Collection Activity 

Hours and Costs Per Report Total Hours 

Managerial 

($139.53/hr) 

Technical 

($67.40/hr) 

Clerical 

($36.05/hr) 

Total 

Hours 

Labor 

Cost1

O&M 

Cost 

Total 

Cost 

Number of 

Respondents 

T

H

U.S. Exporters 

Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 378 

TOTAL 378 

Source: 

(1) Supporting Statement for EPA Information Collection Request Number 2002.05: "Cross-Media Electronic Reporting Rule", June 22, 201Environmental Information, U.S. Environmental Protection Agency 
39

Exhibit 10 

Acknowledgment of Consent Cost Savings 

Information Collection 

Activity 

Hours and Costs Per Shipment Total H

Managerial 

($139.53/hr) 

Technical 

($67.40/hr) 

Clerical 

($36.05/hr) 

Total 

Hours 

Labor 

Cost 

O&M 

Cost 

Total 

Cost 

Savings1

Number of 

Respondents 

Num

Ship

U.S. Exporters - Canada 

Find consent document 0 0 0.17 0.17 $6.13 $0.00 $6.13 326 25Copy consent document 0 0 0.08 0.08 $2.88 $0.22 $3.10 326 25

U.S. Exporters - Mexico 

Find consent document 0 0 0.17 0.17 $6.13 $0.00 $6.13 24 23Copy consent document 0 0 0.08 0.08 $2.88 $0.22 $3.10 24 23

U.S. Exporters - non-OECD

Find consent document 0 0 0.17 0.17 $6.13 $0.00 $6.13 2 2Copy consent document 0 0 0.08 0.08 $2.88 $0.22 $3.10 2 2

TOTAL 352 48

Source: (1) Estimated burden derived from Cost Assessment for the Final Rule on Exports and Imports of Hazardous Waste Destined for Recovery A

of Spent Lead-Acid Batteries from the U.S., and Import Consent Documentation: Office of Resource Conservation and Recovery, Office of SResponse, U.S. Environmental Protection Agency, May 2009. 
40

Exhibit 11 

Exception Report Costs 

Information Collection 

Activity 

Hours and Costs Per Report Total Hou

Managerial 

($139.53/hr) 

Technical 

($67.40/hr) 

Clerical 

($36.05/hr) 

Total 

Hours 

Labor 

Cost 

O&M 

Cost 

Total 

Cost2

Number of 

Respondents 

Numb

Affec

Shipm

U.S. Exporters - Canada 

Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 326 10 

U.S. Exporters - Mexico 

Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 24 9 

U.S. Exporters - non-OECD 

Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 2 0 

U.S. Exporters - OECD

Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 31 1 

TOTAL 383 20 

Source: 

(1) Estimated percentage of shipments requiring an exception report based on e-mail from Phuc Phan on June 5, 2014. (2) Burden estimates from Cost Assessment for the Final Rule on Exports and Imports of Hazardous Waste Destined for Recovery Among OE

of Spent Lead-Acid Batteries from the U.S., and Import Consent Documentation: Office of Resource Conservation and Recovery, Office of SEmergency Response, U.S. Environmental Protection Agency, May 2009. 
41

Exhibit 12 

Exception Report Cost Savings 

Information Collection Activity 

Hours and Costs Per Report Total H

Managerial 

($139.53/hr) 

Technical 

($67.40/hr) 

Clerical 

($36.05/hr) 

Total 

Hours 

Labor 

Cost 

O&M 

Cost 

Total 

Cost2

Number of 

Respondents 

Nu

A

Sh

U.S. Exporters - Canada 

Mail exception report to EPA 0 0 0 0 $0.00 $0.52 $0.52 326 

U.S. Exporters - Mexico 

Mail exception report to EPA 0 0 0 0 $0.00 $0.52 $0.52 24 

U.S. Exporters - non-OECD 

Mail exception report to EPA 0 0 0 0 $0.00 $0.52 $0.52 2 

U.S. Exporters - OECD

Mail exception report to EPA 0 0 0 0 $0.00 $0.52 $0.52 31 

TOTAL 383 

Source: 

(1) Estimated percentage of shipments requiring an exception report based on e-mail from Phuc Phan on June 5, 2014 
42

Exhibit 13 

Movement Document Costs 

Information Collection 

Activity 

Hours and Costs Per Shipment Total 

Managerial 

($139.53/hr) 

Technical 

($67.40/hr) 

Clerical 

($36.05/hr) 

Total 

Hours 

Labor 

Cost 

O&M 

Cost2

Total 

Cost1, 3

Number of 

Respondents 

Num

Ship

U.S. Exporters - Mexico 

Complete movement document 0 0.5 0.5 1 $51.73 $0.55 $52.28 24 23

U.S. Exporters - non-OECD 

Complete movement document 0 0.5 0.5 1 $51.73 $0.55 $52.28 2 

U.S. Importers - Canada 

Send a copy of the movement document to EPA and Environment Canada

0 0 0 0 $0.00 $1.18 $1.18 35 2

Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 35 2

U.S. Importers - Mexico 

Sign movement document and send a copy to EPA, exporter, foreign authority 

0.1 0.5 0.5 1.1 $65.68 $2.36 $68.04 11 3

Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 11 3Maintain a signed copy of the movement document 0 0 0.1 0.1 $3.61 $0.00 $3.61 11 3

U.S. Importers - non-OECD

Sign movement document and send a copy to EPA, exporter, foreign authority 

0.1 0.5 0.5 1.1 $65.68 $2.36 $68.04 3 1

Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 3 1Maintain a signed copy of the movement document 0 0 0.1 0.1 $3.61 $0.00 $3.61 3 1

TOTAL 75 26
43

Source: (1) Burden assumptions based on Supporting Statement for EPA Information Collection Request Number 0820.11 Hazardous Waste Generato

2011.(2) For importer movement document requirements assume $1.15 for international postage and $0.03 for a standard envelope. Based on USPS envelope sent by first-class international letter. (3) Burden estimates from Cost Assessment for the Final Rule on Exports and Imports of Hazardous Waste Destined for Recovery Among OELead-Acid Batteries from the U.S., and Import Consent Documentation: Office of Resource Conservation and Recovery, Office of Solid WasEnvironmental Protection Agency, May 2009. 
44

Exhibit 14 

Movement Document Cost Savings 

Information Collection Activity 

Hours and Costs Per Shipment Tot

Managerial 

($139.53/hr) 

Technical 

($67.40/hr) 

Clerical 

($36.05/hr) 

Total 

Hours 

Labor 

Cost 

O&M 

Cost2

Total 

Cost1, 3

Number of 

Respondents 

U.S. Importers - OECD

Send a copy of the movement document to EPA 0 0 0 0 $0.00 $0.52 $0.52 2 

TOTAL 2 

Source: 

(1) Burden assumptions based on Supporting Statement for EPA Information Collection Request Number 0820.11 Hazardous Waste GeneratoMarch 30, 2011. 
45

Exhibit 15 

Confirmation of Recovery 

Information Collection Activity 

Hours and Costs Per Shipment 

Managerial 

($139.53/hr) 

Technical 

($67.40/hr) 

Clerical 

($36.05/hr) 

Total 

Hours 

Labor 

Cost1

O&M 

Cost2

Total 

Cost 

Number 

of Resp. 

U.S. Exporters - Canada 

Receive and maintain confirmation of recovery provided by the recovery facility 0 0 0.1 0.1 $3.61 $0.00 $3.61 326 

U.S. Exporters - Mexico 

Receive and maintain confirmation of recovery provided by the recovery facility 0 0 0.1 0.1 $3.61 $0.00 $3.61 24 

U.S. Exporters - non-OECD 

Receive and maintain confirmation of recovery provided by the recovery facility 0 0 0.1 0.1 $3.61 $0.00 $3.61 2 

U.S. Importers - Canada 

Send a confirmation of recovery to the exporter, EPA and competent authorities of the country of export 

0 0.2 0.25 0.45 $22.49 $2.88 $25.37 35 

Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 35 

U.S. Importers - Mexico 

Send a confirmation of recovery to the exporter, EPA and competent authorities of the country of export 

0 0.2 0.25 0.45 $22.49 $2.88 $25.37 11 

Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 11 

U.S. Importers - non-OECD

Send a confirmation of recovery to the exporter, EPA and foreign authority 0 0.2 0.25 0.45 $22.49 $2.88 $25.37 3 Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 3 

U.S. Importers - OECD

Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 2 

TOTAL 403 

Source: (1) Burden estimates based on Cost Assessment for the Final Rule on Exports and Imports of Hazardous Waste Destined for Recovery Amon

Lead-Acid Batteries from the U.S., and Import Consent Documentation: Office of Resource Conservation and Recovery, Office of Solid WasEnvironmental Protection Agency, May 2009. (2) Assume $1.15 for international postage and $0.03 for a standard envelope. Based on USPS price calculator for 1 oz. envelope sent by first
46

Exhibit 16 

Confirmation of Recovery Cost Savings 

Information Collection 

Activity 

Hours and Costs Per Shipment T

Managerial 

($139.53/hr) 

Technical 

($67.40/hr) 

Clerical 

($36.05/hr) 

Total 

Hours 

Labor 

Cost 

O&M 

Cost2

Total 

Cost1, 3

Number of 

Respondents 

U.S. Importers - OECD

Send a copy of the movement document to EPA 0 0 0 0 $0.00 $0.52 $0.52 2 

TOTAL 2 

Source: 

(1) Burden assumptions based on Supporting Statement for EPA Information Collection Request Number 0820.11 Hazardous Waste Generato

March 30, 2011. 
47

Exhibit 17 

Laboratory Exemption Costs 

Information Collection Activity 

Hours and Costs Per Shipment Tota

Managerial 

($139.53/hr) 

Technical 

($67.40/hr) 

Clerical 

($36.05/hr) 

Total 

Hours 

Labor 

Cost 

O&M 

Cost 

Total 

Cost2

Number of 

Respondents 

U.S. Exporters - Canada 

Complete and sign movement/tracking document 0 0.5 0.5 1 $51.73 $0.00 $51.73 326 Receive and maintain confirmation of recovery provided by the recovery facility 

0 0 0.1 0.1 $3.61 $0.00 $3.61 326 

U.S. Exporters - Mexico 

Complete and sign movement/tracking document 0 0.5 0.5 1 $51.73 $0.00 $51.73 24 Receive and maintain confirmation of recovery provided by the recovery facility 

0 0 0.1 0.1 $3.61 $0.00 $3.61 24 

U.S. Exporters - non-OECD 

Complete and sign movement/tracking document 0 0.5 0.5 1 $51.73 $0.00 $51.73 2 Receive and maintain confirmation of recovery provided by the recovery facility 

0 0 0.1 0.1 $3.61 $0.00 $3.61 2 
48

Exhibit 17 (continued) 

Laboratory Exemption Costs 

Information Collection Activity 

Hours and Costs Per Shipment Tot

Managerial 

($139.53/hr) 

Technical 

($67.40/hr) 

Clerical 

($36.05/hr) 

Total 

Hours 

Labor 

Cost 

O&M 

Cost 

Total 

Cost2

Number of 

Respondents 

U.S. Importers - Canada 

Sign movement/tracking document and provide a copy to the exporter, EPA, and competent authorities of the country of export 

0.1 0.5 0.5 1.1 $65.68 $1.56 $67.24 35 

Maintain a copy of the signed movement/tracking document 0 0 0.1 0.1 $3.61 $0.00 $3.61 35 Send a confirmation of recovery to the exporter, EPA, and competent authorities of the country of export 

0 0.2 0.25 0.45 $22.49 $1.56 $24.05 35 

U.S. Importers - Mexico 

Sign movement/tracking document and provide a copy to the exporter, EPA, and competent authorities of the country of export 

0.1 0.5 0.5 1.1 $65.68 $1.56 $67.24 11 

Maintain a copy of the signed movement/tracking document 0 0 0.1 0.1 $3.61 $0.00 $3.61 11 Send a confirmation of recovery to the exporter, EPA, and competent authorities of the country of export 

0 0.2 0.25 0.45 $22.49 $1.56 $24.05 11 

U.S. Importers - non-OECD

Sign movement/tracking document and provide a copy to the exporter, EPA, and competent authorities of the country of export 

0.1 0.5 0.5 1.1 $65.68 $1.56 $67.24 3 

Maintain a copy of the signed movement/tracking document 0 0 0.1 0.1 $3.61 $0.00 $3.61 3 Send a confirmation of recovery to the exporter, EPA, and competent authorities of the country of export 

0 0.2 0.25 0.45 $22.49 $1.56 $24.05 3 
49

Exhibit 17 (continued) 

Laboratory Exemption Costs 

Information Collection Activity 

Hours and Costs Per Shipment Tota

Managerial 

($139.53/hr) 

Technical 

($67.40/hr) 

Clerical 

($36.05/hr) 

Total 

Hours 

Labor 

Cost 

O&M 

Cost 

Total 

Cost2

Number of 

Respondents 

S

Transporters

Upon obtaining physical custody of the waste, sign the movement/tracking document 

0 0.01 0 0.01 $0.67 $0.00 $0.67 564 

Maintain a copy of the signed movement/tracking document 0 0 0.1 0.1 $3.61 $0.00 $3.61 564 Upon delivery of the waste, obtain signed copy of the movement/tracking document from the OECD country recovery facility 

0 0.01 0 0.01 $0.67 $0.00 $0.67 564 

TOTAL 965 

Source: 

(1) Affected shipments based on estimates from Cost Assessment for the Final Rule on Exports and Imports of Hazardous Waste Destined for 

Countries, Exports of Spent Lead-Acid Batteries from the U.S., and Import Consent Documentation: Office of Resource Conservation and Reand Emergency Response, U.S. Environmental Protection Agency, May 2009. Ratio of OECD imports/exports for lab analysis and total OEC

(2) Burden estimates based on Cost Assessment for the Final Rule on Exports and Imports of Hazardous Waste Destined for Recovery Amon

Spent Lead-Acid Batteries from the U.S., and Import Consent Documentation: Office of Resource Conservation and Recovery, Office of SoliResponse, U.S. Environmental Protection Agency, May 2009. 
50

Exhibit 18 

Laboratory Exemption Cost Savings 

Information Collection 

Activity 

Hours and Costs Per Shipment Total Hou

Managerial 

($139.53/hr) 

Technical 

($67.40/hr) 

Clerical 

($36.05/hr) 

Total 

Hours 

Labor 

Cost 

O&M 

Cost 

Total 

Cost 

Savings2

Number of 

Respondents 

Numb

Affe

Shipm

U.S. Exporters - Canada 

Find and copy acknowledgment of consent document 

0 0 0.25 0.25 $9.01 $0.00 $9.01 326 1.

U.S. Exporters - Mexico 

Find and copy acknowledgment of consent document 

0 0 0.25 0.25 $9.01 $0.00 $9.01 24 0.

U.S. Exporters - non-OECD 

Find and copy acknowledgment of consent document 

0 0 0.25 0.25 $9.01 $0.00 $9.01 2 0.

TOTAL 352 2 

Source: (1) Affected shipments based on estimates from Cost Assessment for the Final Rule on Exports and Imports of Hazardous Waste Destined for 

OECD Countries, Exports of Spent Lead-Acid Batteries from the U.S., and Import Consent Documentation: Office of Resource Conservation 

Solid Waste and Emergency Response, U.S. Environmental Protection Agency, May 2009. Ratio of OECD imports/exports for lab analysis aimports/exports. (2) Burden estimates based on Cost Assessment for the Final Rule on Exports and Imports of Hazardous Waste Destined for Recovery Amon

Exports of Spent Lead-Acid Batteries from the U.S., and Import Consent Documentation: Office of Resource Conservation and Recovery, OfEmergency Response, U.S. Environmental Protection Agency, May 2009. 
51

Exhibit 19 

EPA Identification Number 

Information Collection Activity 

Hours and Costs Per Recognized Trader Total Hour

Managerial 

($139.53/hr) 

Technical 

($67.40/hr) 

Clerical 

($36.05/hr) 

Total 

Hours 

Labor 

Cost1

O&M 

Cost 

Total 

Cost 

Number of 

Respondents2

U.S. Recognized Traders 

Obtain an EPA ID number - Year 1 0.08 0.34 0.08 0.5 $36.96 $0.52 $37.48 4 

TOTAL - YEAR 1 4 

Source: (1) Hourly burden estimates from: Supporting Statement for EPA Information Collection Request Number 0976.16, "2013 Hazardous Waste 

Notification of Regulated Waste Activity, and Part A Hazardous Waste Permit Application and Modification, September 2012. 

(2) Estimated number of recognized traders based on EPA guidance on methodology table. Note: Recognized traders are estimated to account for 1% of all importers and exporters. 
52

Exhibit 20 

Agency Costs 

Information Collection Activity 

Hours and Costs Per Respondent Per Activity 

Managerial 

($65.58/hr) 

Technical 

($55.50/hr) 

Clerical 

($21.25/hr) 

Labor 

Cost1

Capital 

Cost 

O&M 

Cost 

Movement Document2

Receive and record tracking document from importing country (exports) 222.6 0.00 0.00 $14,600 $0.00 $0.00 Receive and record tracking document from importing facility (imports) 16.21 0.00 0.00 $1,922 $0.00 $0.00 

Confirmation of Recovery/Disposal3

Receive and maintain confirmation of recovery provided by recovery facility (exports and imports) 0.00 0.00 12.87 $273.54 $0.00 $0.00 

EPA IDs for Recognized Traders of Hazardous Waste4

Review letter requesting EPA ID number and enter this information into a database - Year 1 0.00 0.35 0.00 $19.43 $0.00 $0.00 Generate EPA ID number and send EPA ID number to recognized trader - Year 1 0.00 0.00 0.50 $10.62 $0.00 $0.49 

EPA Electronic Reporting System Development5

EPA reporting system development costs (low-end) - Year 1 0.00 0.00 0.00 $0.00 $188,750 $0.00 EPA reporting system development costs (high-end) - Year 1 0.00 0.00 0.00 $0.00 $311,250 $0.00 Labor costs for development, testing, and implementation (low-end) - Year 1 0.00 704.025 0.00 $39,076 $0.00 $0.00 Labor costs for development, testing, and implementation (high-end) - Year 1 0.00 1,173.375 0.00 $65,127 $0.00 $0.00 O&M costs (low-end) - After Year 1 0.00 0.00 0.00 $0.00 $0.00 $170,250 O&M costs (high-end) - After Year 1 0.00 0.00 0.00 $0.00 $0.00 $283,750 Labor costs for maintenance (low-end) - After Year 1 0.00 1,495.66 0.00 $83,015 $0.00 $0.00 Labor costs for maintenance (high-end) - After Year 1 0.00 2,492.77 0.00 $138,359 $0.00 $0.00 

TOTAL (LOW-END) - YEAR 1 

TOTAL (HIGH-END) - YEAR 1 

TOTAL (LOW-END) - AFTER YEAR 1 

TOTAL (HIGH-END) - AFTER YEAR 1 
53

Source: 

(1) U.S. Office of Personnel Management, Salary Table 2014-GS, Incorporating the 1% General Schedule Increase, Effective January 2014, Haccessed at http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2014/GS_h.pdf on August 18, 2014. 

(2) Supporting statement for EPA information collection request number 0820.11, hazardous waste generator standards (renewal), March 30, 

(3) Cost Assessment for the Final Rule on Exports and Imports of Hazardous Waste Destined for Recovery Among OECD Countries, Exports 

the U.S., and Import Consent Documentation. Office of Resource Conservation and Recovery, Office of Solid Waste and Emergency Respon

Agency. May 2009. (4) Supporting Statement for EPA Information Collection Request Number 0976.16, “2013 Hazardous Waste Report, Notification of RegulatHazardous Waste Permit Application and Modification,” September 19, 2012. (5) EPA reporting system development and operation & maintenance costs from the Word Document “EPA FTEs and Costs for import-exporprovided by Phuc Phan of EPA’s Office of Resource Conservation and Recovery on January 15, 2015. 
54

Exhibit 21 

Agency Cost Savings 

Information Collection Activity 

Hours and Costs 

Managerial 

($65.58/hr) 

Technical 

($55.50/hr) 

Clerical 

($21.25/hr) 

Total 

Hours 

Labor 

Cost 

O&M 

Cost 

Cost 

Savings 

Number of 

Respondents 

EPA 

Avoided data entry for export notifications 0 1 0 1 $55.50 $0.00 $55.50 701 Avoided hours answering export notice inquiries via telephone 

0 1,000 0 1,000 $55,504 $0.00 $55,504 1 

Avoided data entry for annual reports 0 4 0 4 $222.02 $0.00 $222.02 378 

TOTAL 
55

Exhibit 22 

 (please note some entities are counted in multiple columns) 

Estimated Number of Respondents Affected by the Proposed Hazardous Waste Export-Impo

Information Collection 

Activity 

Number of Respondents 

U.S. 

Exporters 

(Canada) 

U.S. 

Exporters

(Mexico) 

U.S. 

Exporters 

(non-OECD) 

U.S. 

Exporters

(OECD) 

U.S. 

Exporters

(Other) 

U.S. 

Importers 

(Canada) 

U.S. 

Importers

(Mexico) 

U.S. 

Importers 

(non-OECD

Reading the Rule 326 24 2 31 0 35 11 3 CDX Registration 326 24 2 31 0 35 11 3 Notification 326 24 2 31 318 0 11 0 Re-notification 104 8 1 10 0 0 0 0 Annual Report 326 24 2 31 0 0 0 0 Provide Acknowledgment of Consent to Transporter 

0 0 0 0 0 0 0 0 

Exception Report 326 24 2 31 0 0 0 0 Movement Document 0 0 0 0 0 35 11 3 Confirmation of Recovery or Disposal 0 0 0 0 0 35 11 3 Exemption for Wastes Destined for Laboratory Analysis 

326 24 2 0 0 35 11 3 

Obtain EPA ID 1 1 0 0 0 1 1 0 

TOTAL 326 24 2 31 318 35 11 3 
56

Exhibit 23 

Total Annual Estimated Respondent Burden by Rule Provision 

Provision Total Hours Total Hours (Cost Savings)1 Total Costs Total Cost 

Reading the Rule - Year 1 1,480 0 $130,288.41 EPA Reporting System Registration - Year 1 351 0 $23,917.64 EPA Reporting System Registration - After Year 1 43 0 $2,914.78 Notification - Year 1 755 0 $51,918.04 $Notification - After Year 1 754 0 $21,446.90 $Re-notification 2 0 $164.26 Annual Report 3 0 $211.46 $Provide Acknowledgment of Consent to Transporter 0 12,188 $0.00 $45Exception Report 0.17 0 $11.17 Movement Document 23,721 0 $1,247,256.39 Confirmation of Recovery or Disposal 6,192 0 $250,262.12 Exemption for Wastes Destined for Laboratory Analysis 6 1 $320.26 Obtain EPA IDs (Recognized Traders) - Year 1 2 0 $149.93 

TOTAL - YEAR 1 32,513 12,188 $1,704,499.69 $45

TOTAL - AFTER YEAR 1 30,279 12,188 $1,522,587.34 $45

AVERAGE TOTAL IN THE FIRST THREE YEARS 31,024 12,188 $1,583,224.79 $45

Note: 

(1) For the first three years, there are a total of 43,212 burden hours associated with the proposed rule. Of this, 31,024 hours is the incremental 

the incremental cost savings of the proposed rule. (2) Numbers in parentheses indicate a net cost savings. 
57

Exhibit 24 

Total Average Annual Respondent Burden and Cost Estimates for the First Three Yea

Respondent Type Total Respondents Total Responses 

Number of 

Responses 

per 

Respondent 

Total 

Hours 

Total Labor 

Costs 

Total 

Capital/Startu

and O&M Cos

Private Industry 1,305 7,984 6.1 43,212 $1,128,472 $0 Agency (Low-end) N/A 480 N/A 13,622 $651,878 $127,417 Agency (High-end) N/A 480 N/A 14,443 $697,458 $211,251