Hazardous Waste Export Compliance Register

PROBLEM: EPA's lithium-battery guidance states that international shipments of lithium batteries managed as universal waste must comply with RCRA requirements for export and import of universal waste, and that universal-waste shipments must go to a permitted hazardous-waste disposal facility or recycler as the final destination — yet universal-waste rules do not require a hazardous-waste manifest or a hazardous-waste transporter. The lighter paperwork for universal waste makes the export step the point where a shipment can leave the compliant chain unnoticed.

SOLUTION: An IBM Cloud Ideas compliance improvement that maintains a hazardous-waste export register: every cross-border shipment of universal-waste batteries (and other universal waste) is logged with its destination facility, its permit status, the export/import compliance check and the final-destination confirmation, with any shipment lacking a confirmed permitted destination flagged before it leaves.

EVIDENCE BASIS: DOCUMENTED — EPA, "Lithium-Ion Battery Recycling FAQs": international shipments of lithium batteries managed as universal waste must comply with RCRA export/import requirements; universal waste must go to a permitted hazardous-waste facility or recycler; universal-waste rules do not require a hazardous-waste manifest or hazardous-waste transporter (40 CFR Part 273).