Summary of EPA Final Waste Analysis Plan Guidance

In April 2015, EPA issued a final Waste Analysis Plan (WAP) guidance manual. This guidance manual can assist State regulators in evaluating WAPs and determining whether or not a facility is in compliance with the regulatory requirements. The federal hazardous waste regulations are codified at 40 CFR Parts 260 through 279. This manual can also provide guidance in the development of used oil processor or re-refiner analysis plans in 40 CFR Parts 279.

Summary of EPA 2015 Definition of Solid Waste Rule

On January 13, 2015, U.S. EPA issued a rule that amends its definition of solid waste (DSW) to promote recycling. This rule revises EPA’s previous 2008 DSW rule to provide additional oversight and minimize potential risk of releases to surrounding communities. The following is a summary of the 2015 DSW rule. For more information, go to EPA’s webpage dedicated to the rule here

Comments on the Proposed Management Standards for Hazardous Waste Pharmaceuticals

The Compliance Monitoring and Enforcement Task Force within the Hazardous Waste Subcommittee of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to provide comments on the proposed rule, Management Standards for Hazardous Waste Pharmaceuticals, published in the Federal Register on September 25, 2015 (80 FR 58013). These comments have not been reviewed or adopted by the ASTSWMO Board of Directors. In addition, individual State or Territorial hazardous waste programs may also provide comments based on their own State perspectives and experiences.

Comments on the Proposed Hazardous Waste Generator Improvements Rule

The Compliance Monitoring and Enforcement Task Force within the Hazardous Waste Subcommittee of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to provide comments on the proposed rule, Hazardous Waste Generator Improvements, published in the Federal Register on September 25, 2015 (80 FR 57917). These comments have not been reviewed or adopted by the ASTSWMO Board of Directors. In addition, individual State or Territorial hazardous waste programs may also provide comments based on their own State perspectives and experiences.

ASTSWMO Hazardous Waste Subcommittee Members in Action Fact Sheet

In fulfillment of one of its tasks in its Strategic Plan Work Plan, the Hazardous Waste Subcommittee developed a one-page fact sheet that summarizes what it means to be a member of the Subcommittee and its Task Forces. The fact sheet is based on ASTSWMO’s Members in Action Guidance Document, and it includes the link to the document.

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.