2026 ASTSWMO Position Paper on Recycling

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.

Overview of Hazardous Secondary Materials (HSM) Recycling under RCRA

Due to a technical error the first 10 minutes of the presentation were not recorded, we apologize for the inconvenience.

This presentation will focus on identifying hazardous secondary materials (HSM), how HSMs are regulated under RCRA, and when a HSM is eligible for a recycling exclusion. Examples and case studies will be used to illustrate the most recent definition of solid waste (DSW) exclusions, speculative accumulation, and the definition of legitimate recycling.

Presenters:

Mary Beth Sheridan has worked at EPA’s Office of Resource Conservation and Recycling since 1997, primarily on hazardous waste recycling and the generator regulations. Before coming to EPA, Mary Beth worked as an environmental consultant, a technical writer for McCoy’s Hazardous Waste Consultant, and at EPA’s RCRA/Superfund Hotline.

Tracy Atagi is a national subject matter expert on the Resource Conservation and Recovery Act (RCRA) recycling regulations. She has been with U.S. EPA’s Office of Resource Conservation and Recovery since 1991, working as the team leader on several RCRA-related rulemakings, including rulemakings related to the Definition of Solid Waste, Aerosol Can Universal Waste, Airbag Waste, and Non-Hazardous Secondary Materials.

ASTSWMO Materials Management Subcommittee Comments on 2020 EPA Draft National Recycling Strategy

The Materials Management Subcommittee of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to provide comments on EPA’s Draft National Recycling Strategy and the new U.S. National Recycling Goal to increase the national recycling rate to 50 percent by 2030. The following comments are from the Subcommittee and have not been reviewed or adopted by the ASTSWMO Board of Directors. In addition, individual State or Territorial (State) programs may also provide comments based on their own State perspectives and experiences.

ASTSWMO Recycling Position Paper

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 strategy for recycling. The position paper describes challenges the current system is facing and includes content recommendations for a national recycling strategy.