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.