Dear Colleagues:

A number of industry organizations, including the IPC, has met with the U.S. EPA to discuss actions that could be taken by EPA to expedite raising the toxic characteristic (TC) for lead due to recent EPA pronouncements that existing TC levels for lead are too stringent.

EPA has responded that any attempt to raise the TC level would take years to conclude since a multi-pathway assessment would be required.  As an alternative, EPA has suggested that a management program for specified lead wastes that would either be recycled or landfilled might be established.  Such a proposal would allow certain lead-containing wastes to exist the RCRA Subtitle C hazardous waste management system if they are managed in certain ways.

In order to ensure that the lead-containing residues from printed wiring board manufacture (PWB) are covered by this alternative scenario, I need to hear from you as to which specific PWB wastes should be included.  I also need to obtain as much information as possible as to how those wastes are currently handled.

Please e-mail me at [log in to unmask]

Thank you for your assistance.

Holly Lynch
Director of Environmental and Safety Programs    

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