Copyrighted_ARD®
To: Prospective Supplier
From: ARD Fax 24 hrs 1-786-551-2635
Product: Halon 1301 also known as R13b1 in the refrigeration field. Can also be implemented for other used and or recovered commercial gases.
UN : 1009
Amount Requested: Exportable Quantity : 17-80 Mts
Halon 1301 / R13b1: Export Guidelines and Documentation Requirement
For Import* into the United States the following must be adhered to:
(*Article 5 Countries are presently the only Countries allowed to )
( export if the following matters are abided by. )
Dear Sir,
I understand that you can get access to 70-100MTS over a period of time of Halon 1301. The first exportable quantity mentioned was to be: 41.6 MTs/
Use your contacts to see where in the ministry they have deposits of this gas. The Gas is used primarily as a fire extinguishing gas although it is also used in refrigeration for factory cold storage such as Chocolate factories and ice cream manufacturers. Halon 1301 is recovered, used recycled, or reclaimed product, which is the only designation, allowed for import into the USA. There is some documentation necessary for the import to take place. I will briefly outline and explain the type of documentation necessary for the 41.6 Mts of Halon 1301. Most suppliers documentation are from (3) three or (4) Four FIRE EXTINGUISHER COMPANIES THAT SERVICE DECOMMISSIONED BOTTLES or if taken from compressor systems, that is the Halon was used as R13b1 High pressure refrigeration system then a description of transfer process if converted let say to ammonia.
A fire engineer or fluid mechanic can assist you in preparing the documents. I have listed about 13 documents ( 12 is actual number in that lab results over lap) here that will allow us the greater degree of success in obtaining the import approval, however all 13 documents are not necessary (Keep in mind that you must be able to convince us and more importantly the EPA of the veracity of your proposal). Assemble as much information as possible These Companies (Where the material was recovered) need to supply the paperwork and have a fax and telephone number, or designate a spokesperson which can respond to questions about the material. The fax number is important because during the verification procedure they will receive a fax asking them whether they supplied the product and questions relating to the actual product itself.
Outline of the Halon 1301 Deal:
A- is the first and most important step
*A. Documents/Must get those first then get US EPA approval
THE MOST IMPORTANT rule is assemble as much documentation as you can concerning the product.
B. My Company /Buyer Petitions the US Government for Permit Approval
Petition process takes some time. The US EPA has 41 days to look over the material and approve or reject it.
C. If approved Importation Allowed, and then we open L/C and Buy the Material. Note approval is needed first before we can proceed with BUY. On the L/C the Company giving the documentation get's the Letter of Credit, so make sure if you have this deal that the supplier will allow you to get the L/C under your name or make arrangements ahead of time. Also I can only transfer the Letter of Credit which is a documentary irrevocable Letter of Credit At Sight subject to Buyer's inspection only once. On the issue of L/C I will need an outline of terms acceptable for instance general agreement is: Irrevocable Letter of Credit, documentary, "At Sight" subject to Buyers Inspection, Buyers inspection involves two step process s first upon approval agents will be sent to Halon Location Site for product inspection first stage to see that it is Halon, the second stage is once product reaches the USA the Company will do an analysis to make sure it confirms with 7201 ISO Standard. I am enclosing a copy of the 7201 Standard and copy of sample test so you see what they look like.
Preliminary Definitions:
Previous Source= Where the product came from before the Recoverer recovered the product
Recovery= is the process of extracting the gas
Reclaim= is extracting the gas and then fixing it to International Standards
What type of documents is required well? (Here are some examples)
Document Number 1.
1. Previous Use and Source Description
A. You will need send us a letter, ALL MUST BE ON YOUR SUPPLIERS STATIONARY
The XX Mts is a combination of recovered recyclables from:
1. Name of Corp.
2. Name of Corp.
3. Name of Corp.
A. Address/Province, contact person, phones number, faxes number, e-mail if any, and company details where the previous use occurred;
Previous use is in the fire retardant business
You have to supply names of companies you got from
And quantities, for instance:
ABC Corp address/Tel/Fax provided
10 MTS
XYZ provided 15 MTS address /tel/fax
The more information the better.
Company A let's say received 12,000 bottles of 1.5 lbs per bottle fire extinguishers out of services and decommissioned cylinders, the material was extracted and placed in Bullet 1000lb cylinders for either sales "as is" or reclaimation to U.S. Specification.
If ammonia conversion the type of compressor, pictures, or general description of recovery and transfer process.
DOCUMENT Number 2
B. We need LAB ANALYSIS/ this is like sample attached
15 Cylinders/Ton/1/2/Tons
THIS IS FOR HALON 1301
Result
Purity %MIN 98.5%
Moisture PPM Max 10
Acidity PPM Max 2.5
Residue PPM Max 50
DOCUMENT Number 3
C. Do you have certificates from Ministry export license/this should be easy to get from your business; this of course is not necessary. The local EPA must provide name number and contact where EPA attaché office will be able to call and verify if necessary.
DOCUMENT Number 4
2. Previous Source Listing of names and contacts
SEE A, B, and C above
DOCUMENT Number 5
3. Description of Source Facility
SEE A, B, and C above
4. Brochures from Source Facility DOCUMENT Number 6
5. Government Certification DOCUMENT Number 7
6. Source Certification DOCUMENT Number 8
7. Lab Analysis DOCUMENT Number 9 same as above
8. Reclaim Process Description DOCUMENT Number 10
9. Recovery Process descriptions DOCUMENT Number 11
10. Packing Description including the tanks and picture of Storage
Transport Tanks. DOCUMENT Number 12
11. Separate Previous Use Statements made by suppliers DOCUMENT
Number13
MEMORANDUM
The petitioning and approval process of the EPA is not an easy task, however, through patience and persistence, numerous telephone conversations and meetings with the EPA, our organization has developed a working relationship with the EPA and have received several "non-objection notices" from the EPA for petitions to import used and recoverable material into the United States. The most important three Regulatory Requirements are: 1) Montreal Signature Nation, we will only submit Montreal Signature Nation gases, 2) Independent Verification, EPA under statutory requirement must independently verify, that means they can call any and all individuals listed as "Suppliers" of material, and 3) Previous Use, a detailed " previous use " of the substance must be articulated using as many specifics and details as possible/ refer to "applicable sections Below".
The approval process is a target, which is intended to move beyond the reach of most applicants. However, based on our experience with the EPA, below is a summary of the initial details, which we will require for any submission of a petition to import the used and controlled substances to the EPA.
Details needed for petitioning
1. Company name, address, contact person, telephone and facsimile number of the "source" of the used material. This "source" may be more than one location, and all locations, which have provided the used material, should be listed in detail with exactly how much material was removed from each location.
2. A detailed description of the "previous use" of the material. This detailed description should include details on the machinery which the material was used in, including, if possible, make, model, year of manufacture, and serial number on each individual unit, as well as how much material is used in each unit and how often the material is replaced. Each "source", as noted in 1 above, should have its own listing of this "previous use".
3. A detailed description of the method of extraction of the material, including: the name, address, contact, telephone and facsimile number, license, permit or contract of the company which extracted the material; a description of the machinery used to extract the material, including year of manufacture, make, model and serial number; and date and amount of each extraction of the material by "source" and "previous use".
4. "Source" Country export license or permit, in both the "source" Country language, with appropriate seals and signatures, and English translation, if available for each "source" Country of export, if applicable.
5. If available, certification from the "source" Country of export, which will certify to the reader that they have reviewed information supplied by the exporter and have approved and certify that the material is in fact used and recoverable material, and that the extraction and export of the material is in accordance with the requirements and conventions of the "Montreal Protocol".
I believe that if you can provide us with all of the above information, that, based on our relationship and experience with the EPA, the approval of the petition submitted by us will be forthcoming, however, as you know, there is no guarantee .
Please make sure that all documentation regarding the material clearly states that the material is used and recoverable.
The above will be a start, however, please keep in mind, that after we receive and review the information you provide, we may request additional information prior to submission to the EPA. In addition, we may be requested to provide additional information to the EPA after submission of any petition, which you may need to make available. Please make your suppliers aware of potential contact by the EPA to them or their sources, which may be required by the EPA to verify any information, which we submit.
If you have any questions please feel free to fax me directly at #1-786-551-2635 or e-mail to me at ARDTRADING@AOL.COM.
Phone/Fax: #1-786-551-2635
E-Mail: ardtrades@aol.com
Web-Site: www.ardtrading.com