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RCRA’s recycling legitimacy factors.
Under RCRA, all recycling of secondary hazardous materials for the purpose of exclusion or exemption from the hazardous waste regs must be legitimate. [§§260.43, 261.2(g)] Three recycling legitimacy factors must be met, and a fourth must be considered:
- The secondary material must provide a useful contribution to the process or product.
- The recycling process must produce a valuable product.
- The secondary material must be managed as a valuable commodity.
- The recycler must consider whether the product contains contaminants or exhibits hazardous characteristics that would not be present in a product made with virgin raw materials.
If it’s not legit, don’t do it. Documentation is required [§261.2(f)], and we recommend you obtain written approval of all hazardous secondary material recycling activities from your state. For more compliance morsels, visit our website.
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McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with any guidance provided above. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which such guidance may conflict. Any guidance above is general in nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with environmental 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.
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