State and Federal Regulations allow for characteristic hazardous wastes and non-RCRA wastes to be excluded (conditionally exempt) from hazardous waste laws if the material can meet criteria as outlined in CFR 261.4 and CHSC 25143.2 (b)(d).
These hazardous materials can be accepted by TSDFs as hazardous waste, re-classified as excluded (ERM) and sent to non-permitted recycling facilities for reclamation/ recycling. There are numerous benefits associated with this:
- No landfill
- 1 year accumulation rather than 90 days
- Generators may receive payment for the materials
- Material can be managed as hazardous material, rather than as a waste
- Material can be moved from permitted areas to un-permitted storage space.
Generally, material that can be used as a substitute ingredient or used to manufacture a product is eligible for exclusion. Additional criteria will have to be met, such as matching chemistry and the material may have to have value. Testing is required and a complete audit of the material and process specific to that material needs to be conducted prior to acceptance into the program. This process can be beneficial to generators of such material as well as the environment. It is a win-win situation and Clear Blue is more than ready to service you in this area.
Types of Materials that Qualify
Metal Bearing Products that contain nickel, copper, tungsten, cobalt, aluminum, iron, zinc or other high concentration metal.
Industrial Ingredients including iron oxide, steel powders, aluminum oxide, iron sulfates, calcium carbonate and calcium oxide.