Coating Manufacturers Granted Comment Period for DSW Rule Change
The EPA has granted the American Coatings Association’s (ACA) request for a 30 day public comment period on proposed revisions to the Definitions of Solid Waste (DSW). The revision of the 2008 DSW comes after the EPA cited “serious gaps” in the transfer requirements of secondary waste materials.
The request by the ACA, and the EPA’s acceptance of a 30 day public comment period, makes a lot of sense. Coating manufactures need some time to read through the rule changes and see how they might affect their businesses. Part of the proposed rule change would require reporting on exemptions to the DSW that were not required before. Each exemption would have to be properly documented and sent to the EPA. While this could create more paperwork for coating manufactures and some additional costs, it’s an important step to help reign-in the disposal of hazardous materials used in manufacturing certain coatings and solvents.
In the new rules change, the EPA cites “sham recycling” as one of the reasons the rules had to be adjusted. They’ve found instances of companies passing off the disposal of dangerous chemicals as “recycling” when in reality these chemicals were either being burned or otherwise improperly disposed of. The agency identified 218 cases of recycling damage nationwide when investigating this problem, over half of which were caused by materials that were not originally included in the 2008 DSW. The public comment period for the rules change will end on September 26, 2011. Visit the EPA’s DSW page for additional details.
What do you think? Is the proposed regulation too restrictive and/or will it cost you money? Do you think these changes are necessary in order to help the environment? Let us know.