Position Papers

2021

ASTSWMO Position Paper: Addressing PFAS (3/8/2021) - The ASTSWMO Board of Directors approved the Position Paper on Addressing PFAS in March 2021. The paper acknowledges the work Federal and State agencies have taken to date and recommends federal regulatory action, guidance development, and further research to address… ... Read More

2020

ASTSWMO Recycling Position Paper (8/3/2020) - The ASTSWMO Recycling Position Paper, developed by ASTSWMO’s Materials Management Subcommittee, was approved by the Association’s Board of Directors on July 21, 2020. ASTSWMO recommends EPA consider promoting substantial changes to the country’s recycling system as EPA develops a national… ... Read More
ASTSWMO Statement on ASTM E3225-20 and Testing of Spill Prevention Equipment and Containment SUMPs Requirements in 40 CFR – 280.35 (5/4/2020) - In March 2020, ASTM released E3225-20, Standard Practice for Performing a Liquid Test of Spill Prevention Equipment and Containment Sumps Used for Interstitial Monitoring of Piping by Visual Examination. ASTM E3225-20 provides a practice for inspection of spill prevention equipment… ... Read More

2019

CERCLA Modernization Position Paper (11/19/2019) - The ASTSWMO CERCLA and Brownfields Subcommittee has published a position paper on CERCLA Modernization in which there are specific areas of the Superfund Program where States could contribute in a larger, more significant role which would make the process more… ... Read More

2018

ASTSWMO Position Paper on the Importance of Community Involvement (8/29/2018) - The history of community involvement in the environmental field has been one of staggered improvement across the nation. The process, priority, and status of community involvement differs significantly not only from each of the 50 States and six Territories, but… ... Read More
State Concerns with the Process of Identifying Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Applicable, or Relevant and Appropriate Requirements (2/28/2018) - Over the last five years, the Association of State and Territorial Solid Waste Management Officials’ (ASTSWMO) CERCLA and Brownfields (CaBS) Subcommittee members have been evaluating State and Territorial (State) roles at CERCLA cleanups. One troubling area has been the process… ... Read More

2017

ASTSWMO 128(a) Position Paper (5/17/2017) - On January 11, 2002, President Bush signed the Small Business Liability Relief and Brownfields Revitalization Act (Pub.L.No. 107-118, 115 stat. 2356, "the Brownfields Law"). The Brownfields Law amended the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund) by… ... Read More
Cathode Ray Tubes (CRT) Management Position Paper (4/17/2017) - Due to the fast-paced changes in technology and consumer interest in buying new electronic products, many States are seeing an increase in the amount of older electronic items being discarded. Monitors and televisions with cathode ray tube (CRT) technology are… ... Read More
ASTSWMO Position Paper on Performance-Based Contracting at Federal Facilities (3/17/2017) - Performance-based contracting (PBC) is frequently used for implementing environmental cleanup work at federal facilities under the Defense Environmental Restoration Program (DERP). The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) has produced two white papers on the subject:… ... Read More
ASTSWMO Position on Advanced Geophysical Classification for Munitions Response (1/17/2017) - The Department of Defense (DoD) developed the advanced geophysical classification for munitions response process (hereafter referred to as advanced geophysical classification, or AGC) to improve the efficiency and effectiveness of munitions cleanup.1 AGC represents a major change in how munitions… ... Read More

2016

ASTSWMO Position Paper on RCRA Subtitle C Hazardous Waste Program Information and RCRAInfo Database Operation and Maintenance (10/17/2016) - Since the enactment of the Resource Conservation and Recovery Act (RCRA) in 1976 and subsequent amendments, the U.S. Environmental Protection Agency (EPA) has developed and maintained several information systems. These evolving information management systems are necessary for tracking and maintaining… ... Read More
ASTSWMO Position Paper on Federal Regulation of Coal Combustion Residuals (10/17/2016) - On April 17, 2015, the U.S. Environmental Protection Agency (EPA) published the final rule, Hazardous and Solid Waste Management System; Disposal of Coal Combustion Residuals From Electric Utilities (80 FR 21301). This Position Paper is a brief update from ASTSWMO… ... Read More
ASTSWMO Policy Position on UST Open Bermed Containment Systems (7/17/2016) - This position paper addresses open bermed containment systems that are used to meet the spill prevention equipment requirements for underground storage tanks (USTs) outlined in 40 CFR 280.20(c). Bermed containment systems are configured with small concrete berms or curbing that… ... Read More

2014

ASTSWMO Position Paper on Coal Combustion Residuals (7/20/2014) - This publication has been replaced by this document here. On June 21, 2010, the U.S. Environmental Protection Agency (EPA) proposed the rule, Hazardous and Solid Waste Management System; Identification and Listing of Special Wastes; Disposal of Coal Combustion Residuals From… ... Read More
ASTSWMO Position Paper on 128(a) Funding (5/9/2014) - This paper has been replaced by the document located here. On January 11, 2002, President Bush signed the Small Business Liability Relief and Brownfields Revitalization Act (Pub.L.No. 107-118, 115 stat. 2356, "the Brownfields Law"). The Brownfields Law amended the Comprehensive… ... Read More

2013

ASTSWMO Policy Position Paper on Federal Facilities (10/20/2013) - Environmental compliance and remediation at active, closed, and transferred federal facilities continues to be one of the most complex and controversial issues in State-federal relationships. The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) has consistently supported individual… ... Read More
ASTSWMO Position Paper on e-Manifest Funding (10/15/2013) - 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… ... Read More
ASTSWMO Subtitle D Post-Closure Position Paper (7/16/2013) - Regulations promulgated approximately twenty years ago by individual States under the authority of Subtitle D of the Resource Conservation and Recovery Act (RCRA) include provisions regarding the post-closure care of municipal solid waste (MSW) landfills. The Subtitle D regulations establish… ... Read More
ASTSWMO Position Paper: A New Regulatory Approach to Pharmaceutical Waste Management (4/15/2013) - 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… ... Read More

2010

ASTSWMO Request for Extension of the Comment Period of the Proposed Rule Hazardous and Solid Waste Management Systems; Identification and Listing of Special Wastes; Disposal of Coal Combustion Residuals from Electric Utilities (8/20/2010) - The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) respectfully requests a 120 day extension of the comment period for EPA's proposed rulemaking for the Hazardous and Solid Waste Management System; Identification and Listing of Special Wastes: Disposal… ... Read More