What impact would legislation implementing the Basel Convention have on Laidlaw?

The passage of S. 1082, the Administration's Basel Convention-implementing legislation, in its present form would maintain the status quo for Laidlaw's current operations. However, if the current U.S.-Canadian bilateral agreement requires amendment, the amended agreement would have to be consistent with any new requirements provided for in S. 1082. Laidlaw would comply with any additional requirements in an amended U.S.-Canadian bilateral agreement.

In Laidlaw's opinion, what would be the ideal waste export scheme for the United States to implement?

An ideal scheme would be one that addresses waste exports as well as waste imports in a manner that is consistent with the provisions of the Basel Convention. Such a scheme should take into account the fact that other countries, such as Canada, have standards different from those of the United States, but which nevertheless ensure that waste is dealt with safely and in an environmentally sound manner. Recognizing that mismanaged wastes do not respect borders once released to the environment, responsible generators should have access to environmentally sound treatment and disposal facilities without artificial trade or political barriers.

CONCLUSION

In summary, Laidlaw fully endorses efforts by this Subcommittee and the U.S. Government to put into practice the principles of the Basel Convention. The ratification of the Basel Convention by the United States will help to strengthen the Convention and the emerging international legal regime regarding the transboundary movement of hazardous and non-hazardous wastes. As to enacting implementing legislation, we believe such a measure, while fully protecting human health and environment, should take into account the need to understand and respect the laws of other industrialized countries receiving U.S. waste, and the need to work with them as equal partners in the effective resolution of the complex problems of international waste movement and disposal.

On behalf of Laidlaw, I thank you for this opportunity to present our views and look forward to working with you and your staff as the legislative process moves forward in the months ahead.

ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT

NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
BUILDING 33, BOX 25327, DENVER FEDERAL CENTER
DENVER, COLORADO

18223

DATE May 14, 1991

Ingressman Mika Synar

Chairman, Subcommittee for

Environment, Energy, and Natural Resources 2441 Rayburn Office Building, Room B-187-B-C Washington, DC 20516

Dear Congressman Bynar:

This is in response to your letter of May 6, 1991. to Mr. Jim Vincent of sff concerning statistics on hazardous waste exports and imports.

You requested the total amount of hasardous wastes exported since 1989 and a breakdown by type of waste. Exports to all countries totalled about 141,600 tons for 1989 and 119,200 tons for 1990. About 34,200 tons were exported during the first four months of 1991 for a total of about 295,000 tons since January 1, 1989. Table 1 (attached) gives a breakdown of these exports by type of wasta.

You also requested the destination of these waste exports by country. Table 2 (attached) gives a distribution of exports by year and receiving country. Exports to Canada were about 105,000 tons in 1989, 75,000 tons in 1990, and 29,500 tons through April 80 in 1991 for a total of 202,500 tons. Exports to Mexico were about 28,100 tons in 1989, 39,000 tons in 1980, and 11,700 tons through April 80 in 1991 for a total of 78,800 tons.

Please note that these statistics are for hazardous wastan an defined by the Resource Conservation and Recovery Act (RCRA). Canada defines hazardous wastes to include other wastes such as waste oil and certain recyclable materials not regulated by RCRA. Therefore, Canadian statistics on shipments of hazardous waste between the countries are somewhat higher.

You requested the total amount of hazardous waste imported from Canada and Mexico since 1989. We do not have specific data on Canadian imports responsive to your request. Based on information received from Environment Canada for 1988 and 1989, we have estimated that imports of BCRA hasardous wasta from Canada were about 50,000 tons in 1988 and 78,000 tons in 1989. We have not received similar data from Canada for 1990, but believe imports in 1990 were in excess of 100,000 tons based on published reports of total Canadian exports to the U.S.

only partial data available on imports of hazardous waste from Marion. We do not have an estimate of these imports prior to 1990. The U.S. Customs Service began collecting manifest copies for Mexican imports during 1990 as a courtesy to EPA. Partial data for 1990 indicate that these imports are less than 10,000 tons annually. Most are from maquiladors plants.

Based on the limited information available, we believe total RCRA basardous waste imports from Canada and Mexico since January 1, 1989, are in the range of 180,000 to 220,000 tons.

Thank you for this opportunity to provide information on international shipments of hazardous waste. Please contact me or Jim Vincent at 303/236-6100 if you have any questions or need additional information.

Sincerely,

James&Vincent

Frank M. Covington
Director, NEIC

Attachments

cc:

Raymond B. Ludwiszewski
Acting Assistant Administrator

Based on Annual Reports received by EPA through May 1, 1991.

** Estimate based on Annual Reports received & manifests for companies not submitting Annual Reports.

...

Based on manifests received by EPA through May 1, 1991.