September 18, 2023

ANPRM on Used Drum Management and Reconditioning

On August 10, 2023, EPA issued an advance notice of proposed rulemaking (ANPRM) discussing regulatory and non-regulatory strategies for managing hazardous waste containers through their lifecycle. [88 FR 54537] This ANPRM is a follow-up to a drum reconditioner damage case report published in September 2022. The report (discussed in a previous McCoy Review article) focused on drum reconditioners who receive large quantities of non-RCRA empty hazardous waste containers and the resulting damage from mismanagement.

In the ANPRM, EPA lists potential solutions for addressing these container management issues, including:

The agency is not yet proposing regulatory changes and is only seeking input and comments on these container management options. Comments may be submitted through November 22, 2023 via Docket ID No. EPA-HQ-OLEM-2023-0320. [88 FR 60609]

 


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This document addresses issues of a general nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.