|
|
No longer a product.
Not yet a “recyclable material.”
In California, under the the Title 22 regulations, “recyclable materials” are “hazardous wastes”. [§66260.10] But sometimes a facility may wish to recycle unused or off-spec product. In such instances, that off-spec product is a “retrograde material” and is not a recyclable material or waste, provided it is used, distributed, or reclaimed by the original manufacturer or current owner within one year. This also means that an expired product that is a “hazardous material” [HSC 25501] is by definition a retrograde material.
For example, a hazardous material product expires at a facility in California and, thus, becomes a retrograde material. The facility now has one year to either reclaim it onsite or send it back to the manufacturer for reprocessing. During that one year, the material is not a waste as long as it does not otherwise meet the §66261.2 regulatory definition of waste (e.g., the containers are not deteriorated or damaged, no longer labeled, etc.). Visit us online for additional compliance morsels.
|
|
|
 |
|
|
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.
|
