ASTSWMO Position Paper on e-Manifest Funding

The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) strongly supports the development of the e-Manifest system that is currently underway. We and our member States, Territories and the District of Columbia (States) have supported this system since 2004 because it has the potential to provide the States, the federal government, and regulated industry with significant savings of time and resources as well as better and more efficient delivery of information. The system also can also provide real-time tracking of hazardous waste on our nation’s roads and multi-State data will be available to all users.

The Hazardous Waste Subcommittee Comments on Revisions to “Waste Analysis at Facilities That Generate, Treat, Store, and Dispose of Hazardous Wastes: A Guidance Manual”

The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) Hazardous Waste Subcommittee appreciates the opportunity to provide comments regarding the revision to the U.S. Environmental Protection Agency (USEPA) “Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes: A Guidance Manual”, dated January 2013. These comments reflect input from the Hazardous Waste Subcommittee and some additional State hazardous waste programs; the comments have not been reviewed or adopted by the ASTSWMO Board of Directors. In addition, individual State or Territorial waste programs may also provide comments based on their own State perspectives and experiences.

ASTSWMO Position Paper: A New Regulatory Approach to Pharmaceutical Waste Management

Many studies have demonstrated that pharmaceutical compounds are making their way into the environment. Although little can be done to prevent some pharmaceuticals from reaching environmental receptors, the destiny of waste pharmaceuticals can be controlled. The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) understands that the U.S. Environmental Protection Agency (EPA) Office of Resource Conservation and Recovery is developing new regulations for management of pharmaceutical wastes to replace the December 2008 proposal that would have allowed those pharmaceutical wastes already regulated as hazardous waste under Subtitle C of the Resource Conservation and Recovery Act (RCRA) to be managed as universal wastes. ASTSWMO also understands that while EPA’s forthcoming proposal will be designed to offer flexibility to health care facilities that manage pharmaceutical wastes; it too will only apply to those pharmaceuticals currently regulated as a hazardous waste under RCRA. This Position Paper outlines a more holistic management approach that could apply to all post-manufacturing pharmaceutical wastes, not only those regulated as a hazardous waste. In developing this Paper, several articles and publications were reviewed. A complete bibliography of those reviewed is included.

ASTSWMO Subtitle C and Subtitle D Post-Closure Care Period Final Survey Report

In August 2011, the ASTSWMO Hazardous Waste and Materials Management Subcommittees conducted a joint Subtitle C and Subtitle D Post-Closure Care (PCC) Period Survey that was sent to hazardous and solid waste programs in the States, Territories and District of Columbia (States), to gather information on States’ policies and/or regulations with respect to post-closure requirements beyond 30 years.

Fluorescent Lamp Drum-Top Crusher Survey Results

U.S. EPA and State and Territorial (States) regulatory agencies recommend that mercury containing fluorescent lamps be recycled. One device commonly used by industry at the beginning of the recycling process is the drum‐top crusher (DTC). Studies have revealed significant problems with the release of mercury from some DTCs during operation, and there appears to be variability in how States regulate DTCs (from no regulation to requiring a treatment permit). This survey is to quantify the regulatory posture of States with regard to DTCs, to establish a baseline of knowledge, and assist the ASTSWMO Hazardous Waste Recycling Task Force in its dialogue with U.S. EPA on this topic.

RCRAInfo User’s Manual

This document was developed to provide general data entry guidance to users new to the world of the Resource Conservation and Recovery Act (RCRA) and RCRAInfo and provide “plain talk” instructions on how to understand various aspects of the user screens for each of the modules of RCRAInfo. In this document, a new data entry user will learn how to access the screens, input data, edit information, link data, use shortcuts, and acquire printouts to maximize the effectiveness of RCRAInfo.

ASTSWMO Comments on the December 9, 2011 Report titled “EPA Must Improve Oversight of State Enforcement”

The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) has reviewed the December 9, 2011 report titled EPA Must Improve Oversight of State Enforcement (the Report) and is compelled to respond due to what we believe is a misleading assessment of State Hazardous Waste Program oversight of regulated entities within their jurisdictions. ASTSWMO represents the waste management and remediation programs of the 50 States, five Territories and the District of Columbia (States). Our membership includes State waste program experts in the management and regulation of solid and hazardous waste; therefore, our comments will be directed exclusively toward those issues in the Report pertaining to State oversight under Subtitle C of the federal Resource Conservation and Recovery Act (RCRA).

The Hazardous Waste and Solid Waste Subcommittees provide input on the RCRA Messaging initiative.

The Hazardous Waste and Solid Waste Subcommittees of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciate your invitation to  provide input on the “RCRA Messaging” initiative. In this letter, we offer our perspectives on this initiative and the value of the RCRA Subtitle C and D programs as well as additional State and Territorial (State) programs and their continuing accomplishments. At their heart, the Resource Conservation and Recovery Act and equivalent State programs are pollution prevention and resource conservation programs. This is truer now than when RCRA first became law, as evidenced by substantial reductions in the amount of hazardous waste generated across the nation and shifts towards use of less-toxic, more environmentally friendly materials in manufacturing and production operations. We believe this fundamental shift in thinking was brought about by RCRA and its implementing regulations.

The Hazardous Waste Recycling and Program Information Management Task Forces comment on the Definition of Solid Waste Notice Proposed Rule (76 FR 44094)

The Hazardous Waste Recycling and Program Information Management Task Forces (Task Forces) of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) Hazardous Waste Subcommittee, have reviewed the July 22, 2011 Proposed Rule concerning potential revisions to the definition of solid waste (DSW) at 76 FR 44094. The Task Forces’ comments are enclosed.