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 purpose of this article is to detail one requirement of the conditional exclusion: the requirement at 40 CFR 261.4(a)(20)(ii)(D) for generators or intermediate handlers of a hazardous secondary material used to make zinc fertilizers to maintain at their facility records of all shipments of hazardous secondary materials.  Records must be kept for no less than three years. (more…)