2015 DSW

Revisions to Non-Waste Determinations and Variances From Classification as a Solid Waste by the 2015 DSW

This is another article in a series regarding the 2015 Definition of Solid Waste Rule (2015 DSW) and its affect on the regulations of the USEPA, and state agenices.  The primary goal of the 2015 DSW was to improve the…

40 CFR 261.4(a)(23) The Generator-Controlled Exclusion

The 2015 Definition of Solid Waste Final Rule retained this conditional exclusion first created by the 2008 Definition of Solid Waste Rule.  However, not satisfied with the level of environmental protection it provided EPA strengthened its provisions.  In this presentation…

A Question About Speculative Accumulation Under the 2015 Definition of Solid Waste Rule

A question I received August 9, 2015 (A Sunday!) from a reader of my monthly newsletter: Hello – I enjoyed reading your article on the new RCRA DSW rule.  In your opinion, would the new labeling requirement in 40 CFR…

The New Notification Requirement if Recycling Hazardous Secondary Materials Under the EPA Regulations of the 2015 Definition of Solid Waste Final Rule

The 2015 Definition of Solid Waste Final Rule, which became effective at the Federal level on July 13, 2015, both added new and revised existing exclusions from regulation as a solid waste for hazardous secondary materials that are recycled by…

Amendment to the Speculative Accumulation Provision Under the New Definition of Solid Waste Rule (2015 DSW)

Amendment to the Speculative Accumulation Provision Under the New Definition of Solid Waste Rule (2015 DSW)

In a Final Rule published January 13, 2015 in the Federal Register, USEPA amended the definition of solid waste it had enacted in 2008 (2008 DSW).  The Federal regulations of the 2015 DSW become effective July 13, 2015.  States with an…