Guidance for Evaluating Beneficial Reuse of Non-Hazardous Materials

When considering the beneficial reuse of non-hazardous secondary materials, the most important factor to consider is whether or not use of the material will have a negative impact on human health or the environment.  EPA provides sound guidance on this subject (linked here), even though many have argued (and won court cases) that EPA has no authority in regulating materials that are not waste.  We will address arguments against EPA’s authority over non-wastes in a different post.  In the present case, whether EPA has authority or not is irrelevant if you care about product stewardship, because good product stewardship mandates this same process.  Considering the potential for negative impact on human health and environment is, by definition, product stewardship.  On this basis, I encourage use of the EPA guidance for beneficial reuse of non-hazardous materials

For more information on this topic or other issues associated with the beneficial use or recycling of chemicals or fuels, please email us or call us at 713-568-3651.