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Subject: Classification and transport of liquid mercury - Your advice

Date: 04/13/00 at 10:58 PM
Posted by: Turlough F. Guerin
E-mail: turloughg@hotmail.com
Message Posted:

Greetings:

I have a query that someone from this forum may be able to help
me with --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 containe


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