Hazardous secondary materials pose a significant challenge in terms of disposal and management. When attempting to distill these materials, a critical consideration arises: they cannot undergo the distillation process without being classified as hazardous waste. This classification triggers the need for a hazardous waste manifest, adding a layer of complexity to their handling.
Even if one attempts to distill these materials prior to their intended use, they still retain their hazardous waste designation. This underscores the inherent risk associated with their manipulation. If distillation is deemed necessary, the options narrow down to sending the material to a facility that holds a Resource Conservation and Recovery Act (RCRA) Part B permit or dispatching it to a facility under the generator’s direct control. This latter option grants an exemption, sparing the material from its hazardous waste classification.
While there exist a few exceptions to this general rule, the overarching principle remains: opting to ship such material for recycling inevitably results in its reclassification as hazardous waste. This underscores the delicate balance between environmental sustainability and the regulatory complexities surrounding hazardous materials.
We here at Altiras believe that distilling hazardous secondary materials is a common RCRA violation. Brokers, often unaware or defiant, commit this breach. Shockingly, this happens without the original generators’ awareness, worsening compliance hurdles in hazardous waste management.