The EPA will hold a public meeting on November 19th from 8:30 am - 12:30 pm to discuss an upcoming regulatory proposal that will revise the agency's definition of solid waste in order to encourage recycling.  EPA's rulemaking is intended to modify the current federal hazardous waste recycling scheme to meet two goals: develop a clearer, simpler regulatory system for hazardous waste recycling that adequately protects human health and the environment; and to remove disincentives to the safe recycling of hazardous waste.

The purpose of the meeting is to present and explain regulatory options the agency is considering.  EPA is expected to propose two options: the "Transfer-Based" Option which would exempt all manufacturing by-products that are recycled on-site from the RCRA definition of solid waste; and the "In-Commerce" Option which would exempt all manufacturing by-products that are sent off-site from the RCRA definition of solid waste as long as the materials are sent to a legitimate recycler for reclamation.  

IPC supports the broader "In Commerce" option because many small PWB shops lack the financial resources to recycle their PWB by-products on-site.  Also, efficiencies of scale are usually achieved through off-site recycling facilities.  The States and environmental groups, however, support the "Transfer-Based" Option because they perceive on-site recycling as more environmentally sound than off-site recycling.

I will attend the meeting, which will be held in the Washington, D.C. area (Airport Hilton, 2399 Jefferson Davis Highway, Arlington, VA), and articulate the views of the industry.  

If you have any questions or comments, please e-mail them to me at [log in to unmask]

EPA anticipates proposing the rule in April, 1997.  

Holly Lynch
Director of Environmental and Safety Programs, IPC

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