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Does anybody know the status of the proposed Hazardous Waste
Identification Rule (HWIR) amendement to 40 CFR 261. Is this ever
going to become law?
The reason I ask is that the proposed rule makes several statements
that the proposed "risk-based" hazardous waste listing process is
supposed to "encourage pollution prevention and waste minimization."
I guess it depends on your definition of pollution prevention, but I
fail to see how the HWIR would encourage pollution prevention. I
don't consider changing the regulatory status of a waste to be
"pollution prevention." Is there something in here that I am missing?
I am putting together a justification section for a pollution
prevention program as part of an overall project proposal. In addition
to things like potential costs savings, environmental benefits, and
reducing a companies regulatory burden and liability, I am trying to
look at all of the regulatory drivers for having a pollution
prevention program. Somebody suggested I look at the HWIR. I guess I'm
having trouble seeing how the HWIR (if adopted) would provide any
extra regulatory incentive for having a pollution prevention program
that is not already in RCRA (i.e., required certifying statements on
manifests, biannual/annual reports, and TSD permit applications). Can
anybody shed light on this?
Ron Del Mar
Fluor Daniel Northwest