Earlier this week, ISRI filed written comments with the U.S EPA identifying regulations that have negatively impeded the continued growth of the recycling industry and that are in need of repeal, replacement, or modification.
The filing of our comments was made in response to the Agency’s notice for public comment on “Evaluation of Existing Regulations” in support of President Trump’s Executive Order 13777, “Enforcing the Regulatory Reform Agenda.”
In our comments to EPA, we highlighted the scrap industry’s significant contributions to both environmental stewardship and the country’s economic strength, and made clear that both were dependent upon government policies that understood and recognized these benefits and that promoted their growth. Among the regulations we focused on were Subtitles C & D of RCRA (definition of solid waste); the stormwater Program (need to revise the Multisector General Permit to remove, or at least revise benchmark monitoring with the performance potential of control measures and wet‐weather conditions): the CFC regulations (revision to require removal of refrigerant from appliances and vehicles prior to their delivery for recycling, consistent with the specific language of § 608(b)(1) of the Clean Air Act Amendments of 1990) and TSCA (elimination of the current chemical data reporting requirements for scrap metal imported for recycling.
While it is not clear what the next step will be at EPA, we are working to schedule a meeting with EPA Administrator Pruitt to discuss these issues, and others, with him.