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 – for zinc-bearing 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)(C) for manufacturers of zinc fertilizers to maintain at their facility records of all shipments received of the excluded hazardous secondary materials. (more…)