The current definiton of solid hazardous waste is too restrictive and does not promote recycling of solid materials that are contamiinated by hazardous chemicals. Additionally, the definiton does not allow % weight/weight contamination of hazardous chemical vs. non-hazardous component to be considered when characterizing the waste. Thus, contaminated solids that could go to recycling must be entirely managed as 100% hazardous waste. There are a plethora of tests (TCLP, etc.) that do not have a central decision-tree approach on which tests should be done under what circumstances to properly determine potential for hazardous solid waste recyclability.
And, for mixed biological waste and hazardous waste, EPA has no definition whatsoever on how this waste should be managed; California does have a regulation on such mixed waste.
Comment submitted by P. Norton
This is comment on Proposed Rule
Definition of Solid Waste
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