Retailers Ask EPA to Reconsider Hazardous Waste Proposal

Earlier this month, RILA worked with environmental counsel Beveridge & Diamond, P.C. and the National Association of Chain Drug Stores (NACDS) to submit comments to the Environmental Protection Agency (EPA) outlining the industry’s concerns with a recent Agency proposal. The proposal, which seeks to update the regulations for identification of ignitable hazardous waste under the Resource Conservation and Recovery Act (RCRA), would unduly burden the retail industry and create tens of millions of dollars in new compliance costs, without any meaningful environmental benefits.

Specifically, retailers argue that EPA’s proposal to change the ignitability characteristic is ambiguous, inconsistent with longstanding RCRA rules and guidance, and unwarranted from an environmental, health, or safety perspective.
 

RILA and its members do support some minor technical changes EPA has proposed to the test methods used for evaluating ignitability, but oppose much of the proposal, including:

  • Establishing a new exception to the aqueous alcohol exclusion;
  • Requiring more aggressive methods to determine if a solid waste contains free liquids for the purposes of ignitability – or corrosivity – testing;
  • The claim from EPA that the proposal does not have significant economic impact.

The complete comments submitted to EPA can be found here.

For more information about RILA’s work with the EPA and our environmental compliance offerings, visit the RILA Environmental Compliance Committee Page or contact Andrew Sousa, senior director, environmental programs.

Tags
  • Legal Affairs & Compliance
  • Sustainability & Environment
  • Public Policy

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