What is a Product and What is a Waste?
When you look around your facility it’s important for you to know when you are looking at a product – and therefore not subject to RCRA – and when you are looking at a waste – and therefore subject to RCRA. Unfortunately, not everything comes with a label reading, “Waste for Disposal” or “Product to be Used”. But as the generator of any solid waste you are responsible to make this determination and be able to defend it to a State or Federal inspector. Let’s say for example that during an on-site inspection an inspector for the USEPA’s hazardous waste enforcement division looks in one of your storage areas and proclaims, “those old drums of solvent over there look like waste to me.” “They’re not,” you retort and then quickly add, “As a matter of fact we hope to put those solvents into use sometime soon.” Right there you’ve got a problem on your hands and the challenge before you is to convince the inspector that the drums of solvent you are both looking at are not a waste but rather are a valuable product. How are you going to do that? Below are some questions you should ask yourself about the “products” you see throughout your facility. The answers to these questions will help you to determine if what you see is a product or a waste. Source: Missouri Department of Natural Resources guidance. (more…)
