In accordance with the definition of solid waste, under 40 CFR 261.2(e) Materials are not solid waste when recycled if they are used or reused as ingredients in an industrial process to make a product or as effective substitutes for commercial products, provided the materials are not being reclaimed. Since these materials cannot be reclaimed or process first, we refer to this as “use as is”.
Altiras Chemicals was founded on the basis of “use as is” use of secondary chemicals (byproducts, coproducts, used, offspec, and surplus chemicals). If these secondary chemicals contain listed chemicals or have characteristics that, as a waste, would make them hazardous, they may be considered “hazardous secondary materials” by EPA (40 CFR 260.10). Altiras Chemicals has been very successful in beneficial reuse of hazardous secondary materials when the materials could be used as is. Unfortunately, there are many of these materials that simply cannot be used as is. Sometimes the color is too dark, the material might contain other constituents that would cause problems for the intended use, or there may be “toxics along for the ride.” Because of these issues, many of these materials have continued to be managed and hazardous wastes, even though they may have had very high intrinsic value.
Fortunately, Altiras Recovery has developed solutions for many of these types of products that cannot be used as is. The solution involves careful coordination with generators of the materials, regulatory authorities, and Altiras’ expertise in RCRA regulations, process development, and product markets. If you have hazardous secondary materials that have high intrinsic value, but no market value due to some problem constituent or characteristic, please contact Todd Pencarinha at 713-568-3651 or by email at firstname.lastname@example.org