The US EPA’s View on - Legitimate Recycling of Hazardous Secondary Materials (HSM)

The 2021 Novesis white paper explains the U.S. EPA’s 2018 Definition of Solid Waste (DSW) Rule legitimacy factors and the Generator-Controlled Exclusion (GCE) and Transfer-Based Exclusion (TBE) that allow hazardous secondary materials to be recycled without being regulated as solid or hazardous waste, when specific conditions are met. …

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The USEPA's “Continued Use” Policy Discussion

The 2019 Novesis white paper explains the U.S. EPA’s long-standing “continued use” policy, under which solvents, degreasers, and similar materials remain products (not solid or hazardous wastes) so long as they continue to be used as-is for their purpose without intermediate reclamation or processing. …

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