The ASTSWMO Lithium Battery Workgroup, in collaboration with the Hazardous Waste and Materials Management Subcommittees, has published a position paper which addresses ASTSWMO members’ priorities for future EPA rulemaking on lithium battery requirements under the Universal Waste Regulations. It builds upon the Workgroup and Subcommittees’ earlier input, including a joint early comment letter to EPA in 2024 and a 2025 survey of ASTSWMO’s membership that identified the major challenges members face with lithium batteries. The paper recommends how new EPA rulemaking could resolve issues highlighted by States.
A coordinated, science-based federal regulatory framework – developed and implemented in partnership with States and supported by clear authority, timelines, and funding – is essential to effectively address PFAS nationwide. States are prepared to lead implementation and enforcement, but federal clarity and statutory alignment is needed to ensure consistency, accountability, and progress. The Association urges accelerated development of this framework based on science as understanding of PFAS behavior and impacts continues to evolve.
In March 2026, the ASTSWMO Board of Directors approved an update to the ASTSWMO recycling position paper issued in 2020. The ASTSWMO 2026 Recycling Position Paper supports sustained funding for the U.S. Environmental Protection Agency’s (EPA) Solid Waste Infrastructure and Recycling (SWIFR) and Consumer Recycling and Education Outreach (REO) grant programs. These grant programs address major needs that ASTSWMO identified in the 2020 position paper by supporting activities to improve the infrastructure for recycling, data collection, implementation of State-led plans to advance post-consumer materials management, and recycling education and outreach.
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 and containment sumps by visual examination (“naked eye”) that does not use vacuum, pressure, or liquid testing. This position paper has been revised and retained by the ASTSWMO Board of Directors on October 22, 2025.
Please note: Since publishing this Position Paper, ASTM has updated the Standard Practice for Performing Visual Examination of Containment Sumps (now ASTM E3225-24). The U.S. Environmental Protection Agency (U.S. EPA) has not issued guidance on this updated standard. Consistent with U.S. EPA practice, ASTSWMO will continue to cite the 2020 ASTM Standard.
Superfund is a critical federal program that provides a mechanism for cleaning up properties that pose a threat to human health and the environment. As of January 2025, there are 1,341 sites included on the United States Environmental Protection Agency’s (EPA) National Priorities List (NPL) across the States, Territories and the District of Columbia. These sites are in various stages of the Superfund process. While 458 sites have been deleted from the NPL, EPA is under continued pressure to accelerate cleanups and remove sites from the NPL. Leveraging both State and federal resources is an opportunity to achieve this objective at these Superfund sites.
The revised ASTSWMO Position Paper on Data Quality Issues Within the Hazardous Waste e-Manifest System was approved by the ASTSWMO Board of Directors in October 2024.
The members of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) work every day to provide equal environmental protection to everyone in their States and Territories (States).
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 (States), but also from program to program, and site to site. Community involvement is dependent upon program priorities, agency lead (State, U.S. Environmental Protection Agency [EPA], or other federal agency, such as the Department of Defense [DoD]), program statutory and regulatory requirements, resources, community economic levels, community interest, and project manager focus.
Community involvement is a requirement of most federal and/or State environmental regulations and should be adhered to by all parties. It is important that the State agencies collaborate with the responsible parties to provide uniformity of program implementation. A consistent commitment to community involvement as a programmatic priority will minimize commonly identified challenges. While the commitment needs to be consistent, the approaches should recognize that communities and concerned citizen groups are unique and have specific needs that vary.
Five years ago, the Association of State and Territorial Solid Waste Management Officials’ (ASTSWMO) CERCLA and Brownfields (CaBS) Subcommittee members began evaluating State and Territorial (State) roles at CERCLA cleanups. One constant issue was the process of identifying and accepting States cleanup standards and rules as Applicable or Relevant and Appropriate Requirements (ARARs) in CERCLA cleanups. CaBS and the ASTSWMO Board of directors have updated the 2018 position paper to show that the issue is still a concern.
In April 2023, the ASTSWMO Board of Directors approved an update to the ASTSWMO Statement on Coal Combustion Residuals (CCR) Program Implementation that was initially released in January 2022. The updated statement reflects State and Territorial (State) feedback provided to ASTSWMO in January 2023 regarding implementation of the CCR rule and the State CCR permit program approval process. It also recognizes U.S. Environmental Protection Agency CCR activities since the initial statement was issued.
The ASTSWMO Board of Directors, in April 2023, approved the Position Paper supporting a permanent increase in the standard 128(a) Congressional appropriation. The paper acknowledges that the permanent increase of funding will ensure that State brownfields programs are able to provide the critical support necessary for a robust national brownfields program.
