Polyurethane Processing: American Chemistry Guidelines for Management and Disposal of Hazardous Wastes

Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.

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The American Chemistry Council (“ACC”) issued a guidance document titled:

Guidelines for Management and Disposal of Hazardous Wastes from Polyurethane Processing (“Guidelines”)

ACC states that the purpose of the Guidelines are to:

. . . help downstream processors of polyurethane chemicals (referred to hereafter as processors) manage and dispose of resulting waste chemicals (hazardous) and empty containers in a manner that conforms to federal regulations.

The Guidelines provide a detailed summary of the Resource Conservation and Recovery Act Subtitle C regulations addressing issues such as:

  • What is a Hazardous Waste?
    • Listed Wastes
    • Characteristic Wastes
  • Mixture Rule
  • Exclusions/Empty Containers
  • Hazardous Waste Generator Responsibilities
  • Recordkeeping Requirements
  • Storing Hazardous Waste
    • Satellite Accumulation
    • Hazardous Waste in a Designated Central Accumulation Area
  • Disposing of Hazardous Waste
    • On-Site Disposal Treatment

The Guidelines reference various polyurethane chemicals in its discussion of the Resource Conservation and Recovery Act requirements.

A copy of the Guidelines can be downloaded here.

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Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.
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