The EPA proposed Hazardous Waste Identification Rule (HWIR) will replace 
the mixture and derived-from rules under RCRA, and thus is crucial to 
industry in designating what is or is not hazardous waste in the future.

IPC has completed a draft summary and comment outline for HWIR, and will 
gladly provide it free to any interested party.  We encourage everyone to 
take a look at HWIR and submit comments either to IPC or the EPA or 
both.  IPC will be submitting comments on behalf of the industry.  To 
provide as much weight to our comments as possible, IPC needs feedback 
and data from the industry. 

For example, IPC has compiled a summary table of the proposed RCRA exit 
levels for metals commonly found in F006 sludge.  We need feedback on 
whether any company could exit via these levels.  

Please contact Star Summerfield if you would like a copy of IPC's HWIR 
summary (ph 847/509-9700 x347; fax 847/509-9798; email [log in to unmask]).  

IPC encourages all interested parties to submit comments to the EPA on 
HWIR.  We may have to live with this rule for the next decade or more, 
and right now the rule does not look good.  IPC should have a near-final 
draft of comments finished by April 18, and will provide them to anyone.  
You may copy and submit them on your letterhead.  

All comments are due to EPA by April 22.  If you have questions, please 
contact Holly Lynch in  IPC's Washington office (202/638-6219; fax 
202/296-1074; email [log in to unmask]) or Christopher Rhodes in 
Northbrook (847/509-9700 x306; fax 847/509-9798; email [log in to unmask]).