EPA proposed a rule in July that would change the definition of solid waste under RCRA to require more stringent regulation for certain materials to be recycled. This proposal has several flaws: (1) EPA does not have the authority to regulate materials that are not solid wastes, and many of the materials covered by the rule are not wastes at all, (2) the proposal would not reduce future “damage cases”, which is what EPA says it is trying to do with the rule, and (3) the proposal would negatively impact legitimate recycling activities. All of this raises the question: Why is EPA against recycling?
Keith Belton, Ph.D
Dow