Generators of hazardous waste have been navigating the labyrinth of the Resource Conservation and Recovery Act (RCRA) regulatory program for more than three decades. While industries and the products they offer have seen dramatic changes over that time, the RCRA program has changed little. Not surprisingly, the Agency has heard extensively from stakeholders that the RCRA hazardous waste program is a poor fit for today’s generators other than large-scale chemical manufacturing and similar facilities. These “square pegs in round holes” have led to inconsistency in interpretation, imbalance in enforcement, and imprecise coverage of the wide range of generators. On August 31, 2015, EPA issued a proposal that aims to address, at least in part, these concerns.
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