Full Document:
RCRA Online Number: 14837
Title: CHECKLIST TO ASSIST IN EVALUATING WHETHER COMMERCIAL CHEMICAL PRODUCTS ARE SOLID AND HAZARDOUS WASTE UNDER THE RESOURCE CONSERVATION AND RECOVERY ACT
Document Date: 2013-05-14
To: RCRA Division Directors
From: Devlin
Description: This memorandum transmits a separate revised memorandum that provides guidance and a checklist for evaluating the regulatory status of materials that would, under usual circumstances, be commercial chemical products (CCPs). CCPs are not solid waste if they are appropriately stored or managed for use, legitimately reclaimed, or appropriately stored or managed for legitimate reclamation; CCPs are solid waste if they are abandoned by being accumulated, or by being stored, or treated before, or as a means of, being disposed. The checklist is designed to assist in applying this regulatory structure to specific situations and evaluating whether a particular CCP, managed in a particular way, is a solid waste. If a CCP is a solid waste, it then must be determined if the CCP is listed as a hazardous waste or exhibits a characteristic of hazardous waste. If the CCP is a solid and hazardous waste, it must be managed in compliance with the RCRA Subtitle C hazardous waste management regulations.
Regulatory Citation(s): 261.2, 261.1(c)(8), 261.20
Statutory Citation(s): 3007 Read US Code 42, Chapter 82
Official ORCR Policy: Yes
Associated Topic(s):
Characteristic Wastes,
Identification of Hazardous Waste,
P-wastes,
Solid Waste,
U-wastes |
