International & US Client Information
Convenient U.S. Location
For the convenience of our U.S. clients, we have a terminal in Buffalo, New York. The facility is fully permitted to store and transfer Universal Wastes.
Subject to State Regulations, all materials being transported within the U.S. are subject to CFR (U.S. DOT). Universal waste materials are regulated under 40 CFR, Part 273 (Universal Waste Rule). Depending on the type of waste being shipped and your State Regulations, a straight bill of lading and common carrier may be used.
Once the waste material has been transferred to our processing facility in Ontario, all ongoing environmental liability for that waste is transferred to Raw Materials Company.
Visit the Ownership & Liability Regarding Waste page for more information.
Permitted Waste Carriers and Manifests are not required to ship Universal Waste to our Buffalo facility from anywhere in the United States.
All export documentation is handled by RMC.
Certification of Ownership Transfer and Environmental Liability Release Certificates are issued.
Ownership & Liability Regarding Waste
There is a rapidly growing concern on the part of waste generators, over the issues of waste ownership and on-going environmental liability.
In the United States, the issue of on-going environmental liability continues to be a serious concern for waste generators. In the U.S., it is not possible to transfer legal ownership or liability for waste materials. Even in the case where a Permitted U.S. Waste Disposal Site were to agree to accept ownership of the waste, an agreement which circumvents the law is not a binding agreement, and will not be honoured by the U.S. E.P.A. We are all reading information pertaining to fines, closures and superfund sites. Many generators are already aware that they may well face major costs for cleanup, as former shippers to contaminated sites.
There are NO such "cradle to grave" regulations in Ontario. Ownership and on-going liability are legally transferred to the permitted facility under Ontario law.
Following are excerpts from the Environmental Protection Act (Revised Statutes of Ontario), 1990 amended 1992, printed May 1993.
Chapter E19, Section 42(1) states that "ownership of waste that is accepted by a Waste Disposal Site is transferred upon acceptance by the operator of the site."
Section 42(3) states that "ownership transfer applies only in respect of a Waste Disposal Site holding a valid Certificate of Approval."
Section 42(5) states that "liability as owner of a waste is relieved when that waste is delivered to and accepted by a Waste Disposal Site with an applicable Certificate of Approval."
Section 43 states that "should any waste be sent to a site that has not been approved as a Waste Disposal Site, the waste may be ordered to be the responsibility of the previous owner, by the Director." This reinforces the importance that generators must satisfy themselves that Waste Disposal Sites in Ontario possess a valid Certificate of Approval, clearly authorizing the facility to accept the subject waste(s).
Canada / U.S. - Import and Export Documents
For shipments entering Canada, you will require a Canada Customs Invoice.
A Proforma Invoice is required for loads leaving Canada and entering the United States.
Other documentation may be required as well.
Please ensure you check with your local agency for the most up-to-date information as to shipping requirements.
Most waste materials shipped between the U.S. and Canada require an Environment Canada Notification Letter, and a US EPA Acknowledgement of Consent. RMC can assist with this documentation upon request.
RMC has facilities located in Buffalo, New York, USA as well as Port Colborne, Ontario, Canada. This allows us to receive material from our US and Canadian customers without our customers needing to obtain the above documentation.
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Raw Materials Company Inc.
17 Invertose Drive
Port Colborne, ON L3K 5V5
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