U.S. Environmental Protection Agency	15-P-0172
July 6, 2015
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|	\ Office of Inspector General
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At a Glance
Why We Did This Review
We evaluated the effectiveness of
the U.S. Environmental Protection
Agency's (EPA's) oversight of
hazardous waste imports to the
United States. According to data
from the EPA's 2011 Biennial
Report, hazardous waste
treatment/storage/disposal
facilities in the United States
receive and manage
approximately 90,000 tons of
hazardous waste annually from at
least eight foreign countries.
International agreements establish
a notice and consent process to
ensure the receiving countries are
aware of and properly able to
handle the waste. Once in the
United States, the shipment must
be accompanied by a hazardous
waste manifest.
This report addresses the
following EPA goals or
cross-agency strategies:
•	Cleaning up communities and
advancing sustainable
development.
•	Ensuring the safety of
chemicals and preventing
pollution.
•	Protecting human health and
the environment by enforcing
laws and assuring compliance.
Send all inquiries to our public
affairs office at (202) 566 2391
or visit www.epa.gov/oia.
The full report is at:
www.epa.gov/oig/reports/2015/
20150706-15-P-0172.pdf
EPA Does Not Effectively Control or Monitor
Imports of Hazardous Waste
What We Found
The EPA's actions to ensure that hazardous
waste imports to the United States are
received, processed and managed are
incomplete and ineffective. The EPA is
unable to (1) confirm that all imported
hazardous waste shipments reach their
intended destinations, (2) ensure hazardous
waste shipments are received only by
facilities that are properly permitted to handle
the waste, (3) determine whether there are any lost or unaccounted for shipments
of hazardous waste, and (4) block hazardous waste from coming into the country
without the EPA's consent.
Review of a sample of manifests returned to the EPA found that some shipments
occurred outside the consented time frame, incorrectly identified the generator, or
had unusually long transit times. More than half of the manifests reviewed were not
accompanied by an EPA consent letter or other acceptable documentation as
required by federal regulations. Further, the EPA letters consenting to imports did
not consistently include sufficient information to verify that the types of hazardous
waste shipped are those that have received consent.
Based on our assessment of data in EPA information systems, the EPA has an
incomplete picture of hazardous waste entering the country. This can give rise to
undetected and unenforced violations of federal hazardous waste laws, which
could result in unknown human and environmental exposure to toxic substances.
Also, the EPA does not review manifests or data to identify regulatory violations
and pursue appropriate enforcement actions consistent with federal laws for
importing hazardous waste. The EPA's enforcement options are restricted by a lack
of authority to prevent unconsented shipments from entering the United States.
Recommendations and Planned Agency Corrective Actions
We recommend that the EPA implement controls to ensure identification and
tracking of all hazardous waste import shipments, develop and implement
procedures to identify and pursue administrative and enforcement actions to
address deficiencies in the current process, and seek explicit statutory authority to
prevent the import of hazardous waste without prior and explicit EPA consent.
We revised the draft report recommendations after discussion with the agency, and
the agency now agrees with all recommendations.
The EPA lacks explicit authority
to block imported shipments of
hazardous waste that lack prior
EPA consent. This could lead to
improper handling and disposal,
resulting in unknown human and
environmental exposure to toxic
substances, including solvents,
mercury, lead or other metals.

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