Though a small part of overall fertilizer production in the U.S., the reclamation of zinc from what would otherwise be discarded as a solid waste – if done correctly – can result in a substantial benefit to the environment.  Below is a presentation (also on my SlideShare account) that describes the conditions of 40 CFR 261.4(a)(20).

[slideshare id=64011599&doc=40cfr261-160714041806]

USEPA regulations at 40 CFR 261.4(a)(20) provide for a conditional exclusion from management as a solid waste – and therefore as a hazardous waste as well – for hazardous secondary materials used to make zinc fertilizers.  You can learn more about the full conditional exclusion here:  40 CFR 261.4(a)(20)  Hazardous Secondary Materials Used to Make Zinc Fertilizers.

The conditional exclusion identifies three entities:

• Generator of the hazardous secondary material subject to the exclusion.
• Intermediate handler of the excluded hazardous secondary material (may not be necessary).
• Manufacturer of zinc fertilizer or zinc fertilizer ingredients made from the excluded hazardous secondary material.

The purpose of this article is to detail one requirement of the conditional exclusion: the requirement at 40 CFR 261.4(a)(20)(iii)(D) for manufacturers that utilize a hazardous secondary material to make zinc fertilizers to submit an annual report to the USEPA or their state environmental regulatory agency. (more…)