To determine which regulations apply to recycled materials, the generator should consider what the materials is and the manner in which it will be recycled. State regulatory requirements for generators may be more stringent than those in the federal program. When recycling, how a material is regulated under RCRA (i.e., whether or not it is a solid and potentially a hazardous waste) depends on what type of material it is and what type of recycling is occurring. A material cannot be regulated as a hazardous waste unless it is first determined to be a solid waste. Materials Subject to Full Hazardous Waste Regulation When Recycledĭetermining the Level of Regulation for Hazardous Waste RecyclingĪ determination about a whether or not a waste is classified as a solid waste is the crucial first step in the Hazardous Waste Identification Process.Materials Subject to Alternative Regulatory Controls When Recycled.Recycled Materials that are not Subject to RCRA Hazardous Waste Regulation.Determining Applicable Levels of Regulation.Promoting reuse and recovery is certainly one of the goals of RCRA however, this goal does not take precedence over ensuring the proper management of hazardous waste. Reuse, recycling, and reclamation should be viewed as ways of managing hazardous wastes which, if properly conducted, can avoid environmental hazards, protect scarce natural resources, and reduce the nation’s reliance on raw materials and energy. Many hazardous waste recycling operations may pose serious health and environmental hazards and should be subject to regulation under Subtitle C of the Resource Conservation and Recovery Act (RCRA). Hazardous wastes do not cease to be dangerous simply because they are being reused, recycled, or reclaimed.
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