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…
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…
What is Speculative Accumulation?
Certain wastes that are to be recycled are not considered to be solid wastes, and therefore cannot be hazardous waste and are not subject to RCRA regulations, if the wastes meet the requirements of 40 CFR 261.2(c). In brief, this…