TMG Reverse Logistics - Comment

Document ID: PHMSA-2011-0143-0002
Document Type: Public Submission
Agency: Pipeline And Hazardous Materials Safety Administration
Received Date: July 13 2012, at 12:00 AM Eastern Daylight Time
Date Posted: July 16 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: July 5 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: October 3 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 81095ae3
View Document:  View as format xml

This is comment on Proposed Rule

Hazardous Materials; Reverse Logistics

View Comment

It is important to realize that the vast majority of items returned to a retail store are resold either in the store or on the secondary market. A return center received two categories of returns - consumer returns and product recalls. Roughly half the goods received in a retail return center are sent on to the original manufacturer or their representative. The other half is sold on the secondary market. If an item is deemed to be damaged beyond use or is either pool chemicals, pesticides, solvents, fuel, ammunition, or batteries, it should be considered non-hazardous and still in the stream of commerce, thus not required to be packaged or processed as hazardous materials. If any items, other than those specified above, are processed through the return center and are determined at that point to be hazardous, they would then come under the new proposed legislation. It is important to establish the return center as the point of decision and thus held to a higher standard in terms of employee training and product preparation. This will help insure much better compliance and reduce the burden on thousands of store employees that will never be as well trained. Keep in mind that the position of returns clerk in retails stores is a high turnover position in a store. Compliance at this level will, at best, be poor. As for processing pool chemicals, pesticides, solvents, fuel, ammunition, and batteries, these should be picked up at the store by the manufacturer, similar to what is outlined for car batteries. If you have any questions or I can help in any way please contact me at your convince. You can learn more about my background and experience at http://grevedavis.com/about/curtis-greve/.

Related Comments

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Total: 34
TMG Reverse Logistics - Comment
Public Submission    Posted: 07/16/2012     ID: PHMSA-2011-0143-0002

Oct 03,2012 11:59 PM ET
Gregory Sutherland - Comment
Public Submission    Posted: 09/20/2012     ID: PHMSA-2011-0143-0003

Oct 03,2012 11:59 PM ET
Call 2 Recycle - Comment
Public Submission    Posted: 10/01/2012     ID: PHMSA-2011-0143-0006

Oct 03,2012 11:59 PM ET
NUCON International, Inc. - Comment
Public Submission    Posted: 10/01/2012     ID: PHMSA-2011-0143-0008

Oct 03,2012 11:59 PM ET
RSR Corporation - Comment
Public Submission    Posted: 10/04/2012     ID: PHMSA-2011-0143-0010

Oct 03,2012 11:59 PM ET