Comments on EPA's Proposal to Modernize the RCRA Ignitability CharacteristicComments from the Retail Industry Leaders Association and the National Association of Chain Drug Stores
Docket ID No. EPA-HQ-OLEM-2018-0830
The Retail Industry Leaders Association (“RILA”), the National Association of Chain Drug Stores (“NACDS”), and their members (collectively, the “Retail Associations”) are pleased to submit these comments in response to the proposal of the U.S. Environmental Protection Agency (“EPA” or the “Agency”) to modernize the characteristic of ignitability used for identifying hazardous wastes under the Resource Conservation and Recovery Act (“RCRA”). See 84 Fed. Reg. 12,539 (April 2, 2019).