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INDUSTRIAL-ECOLOGY  April 2000

INDUSTRIAL-ECOLOGY April 2000

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Subject:

Classification and Transport of an Industrial Commodity

From:

"Turlough F. Guerin" <[log in to unmask]>

Reply-To:

Turlough F. Guerin

Date:

Thu, 13 Apr 2000 18:21:39 PDT

Content-Type:

text/plain

Parts/Attachments:

Parts/Attachments

text/plain (92 lines)

Greetings:

I have a query that someone from the Industrial Ecology List that may be 
able to help me with -- even to redirect my query to another list --I have 
set out my query below.

Some Context: I am advising a company that has ~1000kg of liquid mercury 
(98-99% purity) that they would like to sell to a buyer in the US. The 
mercury is currently located in Indonesia. It is the intention of the owner 
of the mercury to sell this material (as a once-off sale) as an Industrial 
Commodity, packing and shipping it according to international shipping 
protocols and its own stringent EHS company policies. The mercury has been 
produced as a by-product from a legal/authorized process (based in 
Indonesia) and will be sold to a buyer that will reprocess the mercury to an 
even higher purity for further sale in the US and internationally. In this 
respect, the liquid mercury is not a waste or hazardous waste.

A complication: I understand that liquid mercury can and is shipped
internationally as an industrial commodity and that a Custom's 
Broker/Freight Forwarder (based in the US) only requires a Commercial
Invoice from the seller/owner (of the liquid mercury) to proceed with the 
purchase.

However, I also understand that liquid mercury could possibly be considered 
a hazardous waste as mercury is listed (or could possibly be categorized) in 
the Basel Convention :

  - directly under Annex I (Waste Streams "Y29 Mercury; mercury
compounds"),
  - could fall under Annex III ("of UN Class Code Characteristics 9 H31 
Toxic - Delayed or chronic which are substances or wastes which, if they are 
inhaled or ingested or if they penetrate the skin, may involve delayed or 
chronic effects, including carcinogenicity").
  - could fall under Annex III ("of UN Class Code Characteristics 9 H32 
Ecotoxic which are substances or wastes which if released present or may 
present immediate or delayed adverse impacts to the nvironment by means of 
bioaccumulation and/or toxic effects upon biotic systems") (see
//www.unep.ch/basel/meetings/sbc/workdoc/manual.htm#Movements for details of 
the Basel Convention).

My Focus: Before securing and going ahead with the sale of the liquid
mercury, I have the following queries...

1. Can the liquid mercury be shipped from Indonesia to US as an Industrial 
Commodity, if it is packed and shipped appropriately, if accompanied by a 
Commercial Invoice (as prepared under Section 141.86 of US Customs
Regulations)? In other words, would such commercial shipping of this
material contravene the Basel Convention or any other related regulation?

2. If the liquid mercury is transported between Indonesia and the United 
States, do the requirements of the Basel Convention apply and if so what (or 
how would I find out) these requirements for liquid mercury?

3. What does the owner (exporter) of the liquid mercury need to do with 
respect to the Basel Convention requirements (if these apply)?
Would this be something that the importer's Custom's Broker/Freight
Forwarder (based in New York) would need to deal with respect to the Basel 
Convention and other requirements?

4. What agencies would need to be involved and would the Importer's Custom's 
Broker/Freight Forwarder typically deal with these other agencies (below)? 
i.e. would the seller have to deal with these?

- US Customs?
- US Dept of Transport?
- US EPA (under the Toxic Substances Control Act, TSCA)
- US Coast Guard for Notification Procedures?

..

I am aware of the Harmonized Tariff Schedule of the United States (HTSUS). 
It would appear, from the HTSUS, that liquid mercury is categorized as 
Section VI of HTSUS "Chemicals & Allied Products" (Chapter 28 - Inorganic 
Chemicals with a Customs Classification of 2805.40.00 for Mercury, which is 
a separate entry under this section). This Chapter states that a duty is 
payable on mercury, shipping entry documents must be presented and then 
examined by US Customs staff, the mercury containers must be labelled 
properly, and properly packaged for shipping -- this seems to be fairly 
straight forward with no reference to any specific regulations, permits, 
Basel Convention requirements, etc.

I would be interested in your feedback on these queries.

Kind regards,

Turlough
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