The regulations of the Resource Conservation and Recovery Act (RCRA) mandate a generator of waste manage it from “cradle-to-grave” meaning: from the first moment of its generation to its final disposal.  However, there are times when something might be regarded as a waste but instead is subject to an exclusion or exemption from regulation.  Samples collected for the purpose of a hazardous waste determination are subject to an exemption from regulation at 40 CFR 261.4(d): the analytical sample exemption.

The purpose of this article is to identify and explain the exemption from all RCRA regulations available to a sample submitted to a lab for analysis subject to the Analytical Sample Exemption. (more…)