Decreasing Financial Liability and Solid Waste One Exclusion at a Time

Given the complex structure of RCRA and the extensive exemptions and exceptions to the Solid Waste rules, there are great opportunities to decrease the potential legal and financial liabilities associated with waste management.  The authors will explore ways to reduce solid waste and hazardous waste, decrease generator status (e.g., “large”, “small” and “very small”), and use the new episodic generation rules to the generators benefit.  The authors will also discuss how correctly classifying and managing waste can greatly affect the amount of effort (money) it takes to comply with RCRA, and how it can reduce liability.  Finally, the authors will explore how remedial work and remediation, can play into or out of generator status, one-time waste codes, episodic generation, annual/biennial waste reporting, Tier 2, and Toxics Release Inventory reporting.  The presentation will include reporting advisements for commonly missed reporting requirements associated with annual reporting when undergoing remediation treatment.

The authors will present ways to effectively use the regulatory framework with the everyday complexities of real world disposal, reuse, and recycling, thereby helping to decrease liabilities and simplify and solve the complexities of waste management.