As you may know, the U.S. EPA has issued a proposed Hazardous Waste 
Identification Rule (HWIR).  This HWIR is intended to replace the 
"mixture and derived-from" rules which were vacated and remanded to the 
EPA in a court case in 1991.  

This HWIR proposal was issued on 21 December 1995 (FR v.60 no.245 pp. 
66344-66469), with an original comment deadline of 20 February 1996.  Due 
to the length, complexity and importance of this rule, IPC has retained 
counsel to analyze and assist with developing IPC comments on behalf of 
the PWB/PWA industry.  

IPC's summary analysis of the HWIR proposal and a draft outline of IPC 
comments are now available.  In addition, the new deadline to submit 
comments to EPA on the HWIR proposal is now 22 April 1996.  Therefore, 
IPC would like to disseminate our HWIR summary across the industry and 
gather data to include in IPC's comments.  If you would like a copy of 
the IPC HWIR summary and comment outline, or of the entire HWIR proposal, 
please contact Star Summerfield at IPC (847/509-9700 x347; fax 
847/509-9798; email [log in to unmask]).  The entire HWIR proposal is over 
100 pages long.  Therefore, IPC will send only the summary unless you 
specifically ask for the full HWIR proposal.  

EPA's stated purpose in proposing HWIR is to reduce any overregulation of 
low-risk wastes captured by the mixture and derived-from rule.  The HWIR 
proposal would establish risk-based exit levels within which waste would 
no longer be considered hazardous and thus no longer subject to RCRA 
subtitle C.  However, the exit levels that EPA proposes are so low that 
IPC does not believe they would provide any substantial relief to our 
industry.  In addition, the testing requirements that HWIR would entail 
would be prohibitively expensive.  

IPC welcomes your interpretation and feedback on the HWIR proposal.