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ASTSWMO Comments on the Proposed Rule, Revisions to the Definition of Solid Waste

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The Board of Directors of the Association of State and Territorial Solid Waste Management Officials (herein referred to as “ASTSWMO”) has reviewed the October 28, 2003 proposed rule (68 FR 61558) containing suggested revisions to the definition of solid waste. The ASTSWMO Board is comprised of 14 senior-level State waste program experts representing all geographic and regional areas of the country, and the comments contained herein reflect their collective technical opinions regarding major aspects of the rule proposal. The Board is submitting this letter stating its support of separate comments submitted to the Docket by ASTSWMO’s Hazardous Waste Recycling Task Force (“Task Force”) regarding three areas discussed in the proposal of significant importance to States: notification, legitimacy criteria, and exclusion of on-site recycling. Individual States will also submit comments reflecting their own unique perspectives on the proposed components of the rule.