Dear Colleagues:

The Lead Industries Association is organizing a meeting with U.S. EPA to discuss exempting certain lead-bearing wastestreams from RCRA Subtitle C as long as they are managed/recycled in an environmentally sound manner (i.e., recycled).  

On behalf of the PWB/electronic assembly industry, I would like to submit a list of lead-bearing wastestreams, currently not exempt from RCRA Subtitle C that could benefit from a "contingent management" excusion.

For PWB shops, I presume that shredded circuit boards should be included on that list.  Please e-mail me others.  For assemblers, I presume that solder paste waste and solder paste cleanup wipes should be included.  Please e-mail me others.

Also, EPA is intersted in hearing how industries manage these waste streams.   IN other words, are they recycled in an environmentally sound manner.  The meeting is 1/28/97; therefore, I would appreciate hearing from compliancenet members in a timely manner.

Thank you,


Holly Lynch
Director of Environmental and Safety Programs
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