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ISRI Submits Comments
Regarding Definition of
Solid Waste
June 25, 2007
ISRI submitted comments on U.S. EPA's Supplemental
Proposed Rule on Revisions to the Definition of
Solid Waste. The Proposed Rule includes exclusions
from the definition for "hazardous secondary
materials" that are recycled and reclaimed under
certain scenarios and regulatory language on
legitimate recycling. Existing exclusions would
remain exactly as they are.
ISRI's comments offer general support for the
proposed exclusions and language on legitimate
recycling but opposed certain conditions of the
exclusions as inconsistent with "recycling is not
disposal" and requested clarifications concerning
legitimate recycling.
ISRI also requested, in light of the proposed
exclusions, that scrap materials be excluded from
the definition of solid waste and, barring that,
that unprocessed obsolete scrap metal be added to
"excluded scrap metal" for exclusion from the
definition under the existing scrap metal exclusion.
Questions and requests for information should be
directed to David Wagger, Director of Environmental
Management, at davidwagger@isri.org
or
202/662-8533.
Click
here to view comments (PDF)
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