Some of our frequently asked questions.
As a generator, when does my cradle to grave liability begin and end?
For a generator, liability begins when the waste is generated. There is a temporary transfer of liability to the transporter when the waste leaves the facility and is in the transporter’s possession. The generator is protected from loss by the insurance policy of the transporter which is a minimum of $1 million. The load crosses the U.S./Mexican border using a standard Uniform Hazardous Waste Manifest under the authority of the U.S. EPA or other state agency such as DTSC in California on behalf of EPA. When the load crosses the border into Mexico the authority of the EPA ends. They have no jurisdiction in Mexico.
A new Mexican manifest is created at the border with the IMPORTER OF RECORD accepting generator (Cradle) liability. The waste is now under the regulatory authority of SEMARNAT, which is equivalent to the EPA. Conversely, SEMERNAT has no jurisdiction in the U.S. For all practical purposes, the Cradle to Grave liability has ended for the U.S. generator and begun for the IMPORTER of record in Mexico. The importer of record is RECICLADORA de TEMARRY. The waste arrives at the Temarry facility within about 1 hour after crossing the border and clearing customs. Waste is received and fingerprinted within 1 day and is treated by distillation or thermal treatment within 2 weeks. The Cradle to Grave liability chain is completed after treatment. The waste is gone and long term liability ended.
Is there long term liability associated with ash from thermal treatment or still bottoms from solvent recovery?
No. Ash is blended with still bottoms. The controlled blend is sent to cement kilns to be used as a source of alternative fuel. Nothing goes to landfill. Everything is used. The process represents “True Recycling”
Are there facilities similar to Temarry that serve the Western United States?
No. There may be other companies that offer solvent distillation. There may be other companies that offer Non Hazardous or Non RCRA Waste to Energy processing. To our knowledge there are no other facilities that use solid hazardous waste to generate energy to operate solvent recovery stills.
Why should a generator direct their waste to Temarry Recycling?
Because Temarry Recycling offers the highest level of sustainability with the smallest carbon footprint and, “Recycling isn’t a luxury, it is a necessity”.
