Comments on Management Standards for Hazardous Waste
The Retail Industry Leaders Association (“RILA”), the Food Marketing Institute (“FMI”), the National Association of Chain Drug Stores (“NACDS”), the National Retail Federation (“NRF”), the National Grocers Association (“NGA”), and their members (collectively, the “Retail Associations”) are pleased to submit these comments in response to EPA’s proposed rule, entitled “Management Standards for Hazardous Waste Pharmaceuticals,” 80 Fed. Reg. 58,014 (Sept. 25, 2015) (“Pharmaceutical Proposal”). In particular, the Retail Associations appreciate the opportunity to comment on the proposal to streamline the Resource Conservation and Recovery Act (“RCRA”) regulations as they apply to retailers of prescription and over-thecounter pharmaceuticals (“OTCs”) and dietary supplements. The Retail Associations are also submitting, under separate cover, comments on EPA’s companion proposal to establish new rules for managing other hazardous wastes under RCRA. See 80 Fed. Reg. 57,918 (September 25, 2015).