### Summary of Stakeholder Comments By Topic **(Waste Minimization and Recycling) Stakeholder:**  State of Wyoming **Topic: Clarify on -**  **site recycling of HW Comment:**  More specific information needs to be provided in the generator rules section, addressing the onsite recycling of hazardous wastes. S pecifically, this information should address the types of wastes that can be recycled, examples of situations where recycling is allowed, the types of recycling options that are allowable, and examples of those situations where recycling is not allowed. Regulations prohibiting accumulation of wastes prior to recycling should also be clarified. T he SHWD i s also concerned that in some cases, there are not adequate controls addressing the potential for spills/releases from non - hazardous solid wastes containing hazardous constituents. Stakeholder: State of Wyoming **Topic: R**equire compliance with certain waste minimization requirements **Comment:** It is the SHWD opinion there needs to be regulations requiring compliance with certain waste minimization requirements since this would also greatly help to further decrease and in some cases, eliminate the amount of hazardous waste generated. Stakeholder: State of Wyoming **Topic:** Grant some type of amnesty from certain generator requirements for those generators making major waste minimization and pollution efforts **Comment:** The SHWD is also in favor of the idea of granting some type of amnesty from certain generator requirements for those generators making major waste minimization and pollution efforts. **Stakeholder: State of Michigan**  **Topic: Develop a process for state variances of innovation**  **pollution prevention projects Comment:**  **Develop a process for state variances of innovation pollution prevention projects. Stakeholder:**  **Navy Department Topic:**  Conditional Exclusion from the definition of solid waste at 40 CFR 261.2 for materials if they are recycled. **Comment.** In order to foster a program improvement strategy with the goal of pollution prevention and reduced compliance costs, EPA sho uld consider a Conditional Exclusion from the definition of solid waste at 40 CFR 261.2 for mterials if they are recycled. Discussion. 40 CFR 261.4(a) provides exclusions from the definition of solidwaste for specific recycled materials such as spe nt sulfuric acid used to produce virgin sulfuric acid, excluded scrap metal being recycled, shredded circuit boards being recyc led, etc. Similar exemptions are contained in 40 CFR 261.6(2) for lead acid batteries and used oil. The purpose of such exemptions is to facilitate known recycling processes. In contrast, solid wastes that could be recycled, but that are not specifically exempted from RCRA regulations, are subject to onerous permitting, tracking, and reporting requirements. These RCRA hazardous waste requirements impede market forces that would otherwise prompt industry to seek suitable uses for used materials. RCRA regulat ions are a disincentive and are detrimental to the recycling of materials when regulated as hazardous waste. Recommendation. EPA should devise a Conditional Exclusion under the definition of solid waste to exclude materials that will be recycled, therebyremoving the disincentive to develop and pilot new recycling technologies.

Stakeholder: CBL Industrial Services Topic: Waste minimization certification on HW manifest Comment: I have personally discussed this issue with a number of officials from various State DOT’s around the country. Based on those discussions, it appears that signing the generator certification on the Hazardous Waste Manifest has become a “token” guarantee. Their cer tification seems to mean that the generator has “ a progra m in place to reduce the volume and toxicity of waste generated...”. In truth, those programs have not evolved in 15 years. There appear to be few, if any proactive programs that serve to “raise the bar” or in some way encourage further hazardous wa ste min imization or complete prevention. In fact, one northeastern state DOT recently indicated that they could not use any other system than rec yclable blasting systems because of this federal hazardous waste certification program. They either poorly understood what the certification meant, or simply used it as a justification to continue only using recyclable blasting systems for lead paint abatement projects. We are aware of two diffe rent state DOT’s in the northeast engaged in additional research to see if the re is a better alternative available to hazardous waste generation. For one DOT, the incentive came from its environmental department who clearly understands the importance of hazardous waste prevention, but the issue only re ceived serious consideration after the state quadrupled the Generator Hazardous Waste tax. Without the additional incentive, that generator would have simpl y continued the same program they put in place 15 years ago. The other DOT engaged in hazardous waste reduction after local, po liti cal pressure forced them to do so. Clearly, since the primary focus for the DOT’s is
- and should be
- on the construction and maintenance of the transportation infrastructure, it appears little is being done on hazardous waste management issues until an e conomic disincentive or political pressure arises. Since waste management issues can be secondary for DOT projects, it is not surprising to find ourselves in today’s situation. The DOT’s a re focused on issues of structure construction and maintenance. This is why it is important that EPA become involved, since one of the stated goals of this ANPR is “to foster ... a pollution prevention stewardship philosophy”. b. Alternative Solution It is probably reasonable to continue requiring generators to sign the certification on the Hazardous Waste Manifest. However, more “teeth” need to be included within the certification program. This might include:  Proof that the generator has a waste minimization program in place;
 A reporting requirement showing a net cha nge in unit hazardous waste generation rates year to year (Data already being collected in the Biennial Reports). EPA could simply measure and compare the amount of hazardous waste being produced each year. The EPA Biennial report captures this information , so data is already available for EPA to measure. Decreases of reported hazardous waste quantities may suggest that an effec tive program is in place and would give EPA a measurement tool. The EPA penalize generators who don’t embrace new technologies, but reward those that continually move towards the elimination of the generation of hazardous waste.
 Monitoring waste reduction reports and assessing additional fees if waste reduction improvements are not met. For steel structures maintenance industry lea d abatement projects, there are several abrasive pre
- treatment technologies that have been available for a number of years that prevent the generation of hazardous spent abrasive waste. At least one of these technologies was success fully tested under the U S EPA CRADA Program (USEPA National Risk Management Research Laboratory, 2000). Some DOT’s have been allowing and specifying us e of these hazardous waste elimination technologies use for a few years, but a majority of the state DOT’s still require recyclab le blast systems and dispose of the residues in Subtitle C landfills. The largest barrier to elimination of this hazardous waste generation practice appears to b e an overall resistance to change by the structure owners (DOT’s) and contractors (both cogene rators of the waste) who already use the recycled grit systems. They believe the problem was solved by minimizing the volume of hazardous waste in the early 90’s and have been reluctant to make additional c hanges. As mentioned above, waste management issue s are not central to preserving a large bridge structure, so waste management understandably can receive little, additional thought, particularly when the DOT’s believe they addressed the problem in the early 90’s.

Stakeholder: Linden Industrial Association Topic: Clarify purge solvent, rinse solvent or other cleaning agent is part ofthe manufacturing process until such agent is spent

Comment: RECYCLE STREAMS: By careful definition of recycle streams, the Agency has several opportunities to prevent pollution, enhance the competitive position required to preserve the U.S. manufacturing employment base and to minimize the administrative burden pl aced on EPA and its inspectors. In particular, the clear statement that a purge solvent, rinse solve nt or other cleaning agent is part of the manufacturing process until such agent is spent would have tremendous impact. By recognizing that such materials have ongoing beneficial reuse, the Agency would be making it clear to inspectors that such items are process materials until such a time as they no longer function in the clean or purge role. This would remove burden on Part BB and Part CC tank/manifold operators, minimize recordkeeping and optimize the enviro nmental benefits gained from reuse of materials. This policy would also benefit batch manufacturers who have changeovers between batches. By recognizing that the cleaning materials have beneficial reuse, the Agency would be helping to prevent pollution (as opposed to mandating the immed iate di sposal of such materials after first use). Stakeholder: Linden Industrial Association Topic: Consider the im pact on reuse of by

products of reaction Comment: Please consider the impact on reuse of byproducts of reaction. As an example, for companies manufacturing materials where water is generated as a byproduct of reaction, it can be helpful to save some or all of the water as starting material for subsequent batches, and some or all of the azeotropic solvent (if any) for use in subsequent batches. These are materials which, taken as stand - alone items, would be categorized as hazardous waste. By storing these materials for subsequent re - use, the company involved should not be considered as storing hazardous wa ste. These should be classified as raw material items. As another example, please consider the case of a run or a batch of material that does not meet specification as produced. The manufacturer reprocesses the material in an attempt to render it suitable for sale. The reprocessing fails. The manuf acturer then declares the material to be waste. There is the (errant) potential for someone to consider that the manufacturer treated hazardous waste, when in fact it wa s simply an operating step that failed to produce saleable material. If operators of facilities are not given the incentive to find beneficial reuse for materials, they wi ll cease to try and the result will be an increase in the generation of hazardous waste. Stakeholder: Linden Industrial Association Topic: C onsider the case of a mate rial manufactured in a solvent or solvents that does not meet specification as produced. Comment: As a last example, please consider the case of a material manufactured in a solvent or solvents that does not meet specificat ion as produced. If the manufa cturer distills the product in order to reclaim the solvent for beneficial reuse, this should not be considered as treatment of hazardous waste. This is waste minimization. Stakeholder: Linden Industrial Association Topic: T he economy and industry would benefit from the selection of the **three -**  **digit NAICS designation** as the choice for allowing an exemption for reuse, recycling or reclamation. **Comment:** NAICS CLASSIFICATION AS A BASIS FOR ALLOWING INTER/INTRAFACILITY REUSE, RECYCLING OR RECLAMATION OF MATERIALS: The Agency, the economy and industry would benefit from the selection of the three
- digit NAICS designation as the choice for allowing an exemption for reuse, recycling or reclamation. This is due to the fact th at so many operations qualify under a large number of four
- digit sub
- categories under NAICS. The chore of listing all applicable codes would be a huge burden on industry, an administrative challenge for the Agency and an u nnecessary expense for all involve d. By allowing the broader three
- digit classification to hold sway this would facilitate the administration, effectiveness and pollution preventionpotential of the program. The comments of the Synthetic Organic Chemical Manufacturers Association (SOCMA) a re fully endorsed and supported with

respect to a conditional exemption for “specialty batch chemical manufacturing facilities” within the NAICS code (325) associ ated with chemical products and processes. Stakeholder: ESS Group Topic: Reporting of Waste Min activities in BR - re - institute Comment: 40 CFR 262.41. 40 CFR 262.41(a)(4), (6), and (7) require that the name and EPA ID number of each transporter used during the reporting year, the efforts undertaken during the year to reduce the volume and tox icity of waste generated, and a description of the changes in volume and toxicity of waste actually achieved during the year in comparison to previous years be included in the biennial report filed by the ge nerator. On the 2003 report, this information was not included in Form 8700
- 13 A/B and therefore was not reported by generators. We recommend that the language in this section about the contents of the report be revised not to state what must be included on the form, but just to state that the conten ts o f the form will be determined by EPA. Stakeholder: ESS Group Topic: Reclamation of L ead
- acid batteries and LDR requirements Comment: 40 CFR 266.80(a).This section requires that lead
- acid batteries being reclaimed that will be reclaimed other than through regeneration are subject to the land disposal restriction regulations. We suggest this requirement be removed. Please see the discussion under “40 CFR 268.7” below. Stakeholder: National Pollution Prevention Roundtable (NPPR) Topic: Investigate opportunities to measure performance and environmental results which recognize P2 efforts Comment: EPA needs to investigate opportunities to measure performance and environmental results which recognize P2 efforts. These wou ld include reductions in the a mount of hazardous waste produced, (normalized for productivity), and reduced accidents (accounting for total amount of material/waste released). Also, facilities should be encouraged to report reductions in energy usage, water consumption and other enviro nmentally beneficial activities which are not part of the routine RCRA reporting requirements. EPA should be willing to provide the resources necessary to encourage generators to practice P2 and recycling. This can be do ne by increasing the existing P2 gr ants to state programs funding to the level authorized in the Pollution Prevention Act of 1990, which is $8 million. This wou ld be an increase of $2 million nationally. In addition, EPA should consider increasing the RCRA state grants by $20 million for P2 technical assistance to hazardous waste generators. This level of funding would be a good start in providing local assistance, especially to small and medium
- sized enterprises. NPPR’s report, “An Ounce of Prevention is Worth Over 167 Billion Pounds of Cur e: A Decade of P2 Results 1990

– 2000” (www.p2.org/p2results ) indicates that for every dollar spent on P2 programs and activities, there have been five dollars in cost reductions for industry. That would mean a $ 100 million economic benefit. Stakeholder: Tennessee Valley Authority Topic: Require the waste minimization certification on the annual or biennial report Comment: The regulations should be re
-written to require the waste minimization certification statement for large quantity generators to be on the annual or biennial report rather than on the manifest. Often the person signing the uniform hazardous waste manifest, where the certification statement now resides, does not have control, connection with, or a uthority over waste generation or site chemical procurement. Stakeholder: American Airlines Topic: EPA should notify stakeholders that a waste minimization program isnot a quota or quantity - based program, but rather one in which continuous improvement is sought and incentivized in an attempt to minimize the amount of waste generated **Comment:** Waste Minimization. The major stumbling block to successful implementation of the waste minimization program is that, due to the lack of specific best
- management- practices - type requirements fo r waste minimization, many inspectors are asking for complex, quota
- driven waste minimization programs. In other words, inspectors are asking for companies to quantify the amount of waste generated each yea r and to achieve a certain percentage reduction in waste generation as compared to previous years. This is a very expensive, time consuming, and often impossible endeavor

– especially where other government agency regulations (e.g. FAA) mandate the use of specific processes and materials in produc tion pro cesses. EPA should notify stakeholders that a waste minimization program is not a quota or quantity
- based program, but rather one in which continuous improvement is sought and incentivized in an attempt to minimize the amount of waste generated. In many wa ys, the waste minimization program could be patterned after the stormwater pollution prevention plans under the Clean Water Act. Such plans, in effect, require compan ies to evaluate their process and look for ways to better protect storm water, but do not necessarily require numeric goals to b e met. As indicated above, one significant problem that exists under the current standards is the fact that certain industries are u nder the purview of other Federal agencies. A good example is that all aerospace com panies are regulated by the FAA, and are mandated to use certain chemicals, solvents, paints and processes specified by FAA. Because of this fact, the companies are not free to make changes in their processes to reduce waste generation and often cannot mee t numeric requirements for the reduction of waste. As such, American recommends that the EPA work directly with the FAA and a ircraft manufacturers to find means to reduce the required use of chemicals, solvents, and paints on aircraft. Stakeholder: State of Georgia Topic: Undertake changes in the regulations to require large quantity generators to submit a hazardous waste reduction plan, with established minimum requirements, along with their BR Comment: The manifest certification for generators to certify that they have a waste minimization program in place is not effective. G eorgia has a requirement for all large quantity generators to submit a hazardous waste reduction plan to EPD every other year. EPD believes this state requirement for a formalized plan has resulted in significant waste reduction that would not have occurred otherwise. We would like to see EPA undertake changes in the regulations to require large quantity generators to submit a haza rdous waste reduction plan, with established minimum requirements, along with their Biennial Report. Along the line of r eporting, we believe EPA should consi der a periodic re - notification requirement for all hazardous waste generators. This would reduce t he amount of personnel resources expended inspecting facilities that have stopped generating hazardous waste or went out of business and did not notify EPD of such; and 

### .......... Stakeholder: Pacific NW National Laboratory Topic: : Question the value of certification that the company has a pollution prevention program on the manifest Comment: 262.20(a): Question the value of certification that the company has a pollution p revention program on the manifest. In compa nies of size, certification of a man ifest is performed by staff that may have little or no responsibility for policy development. While such staff may be aware o f a pollution prevention program at their company, they may not be able or qualified to determine if it meets all of the requirem en ts specified in the certification. EPA has made several accommodations concerning this certification in the past.13 In the 20 years since Con gress mandated this certification, pollution prevention has become broadly available and widely utilized. The value of the certification is no longer evident, and we encourage EPA to consider removing it. This change would require Congress to remove the statutory requirement for the certification found at 42 USC 6922(b).Stakeholder: Electronic Industries Al liance (EIA) Topic: Listing of F006 electroplating sludges

Comment: The Effluent from Treatment of Electroplating Wastewaters Reused On
- site should be Exempt from the Potential to Generate F006 . Under 40 C.F.R. § 261.31, the listing of F006 applies to sludges generated from electroplating wastewaters. By definition, electroplating wastewaters, unless they exhibit a hazardous characteristic, are not hazardous waste. However, under the listing, any sludge generated fro m the wastewater is considered a haza rdous waste, regardless of whether it actually exhibits a hazardous waste characteristic, or if it even contains any of the c onstituents for which the listing was made in the first place. This interpretation has created a great deal of confusion in the ele ctronics industry and resulted in overly conservative management of electroplating wastewaters

— to the point that many of these wastewaters are treated and directly discharged to POTWs rather than reused onsite because of their potential to generate F006. This overly conservative management of electroplating wastewaters is due in part to inconsistent EPA guidance that makes reus e difficult. An example from the semiconductor industry highlights this inconsistency. In the proposed Metal Parts and Products ru le, the EPA Office of Water Quality clarified that semiconductor operations do not involve “electroplating.” 66 Fed. Reg. 433
- 434 (January 3, 2001). Since the EPA Office of Solid Waste used the Office of Water Quality definition of “electroplating” when it created the F006 listing, it is reasonable to assume that wastewaters generated from semiconductor manufacturing cannot generate F006 because they do not come from “electroplating” operations. See EPA Interpretative Rule, 51 Fed. Reg. 43350 ( Dec. 2, 1986 ) (“As explained in the Listing Background Document for F006, the Agency identified the listing for “electroplating operation s” to cover the same processes as was included under the Effluent Guidelines Division’s pretreatment standards for the electropl ati ng point source category.”) However, shortly after the Office of Water Quality took the position that semiconductor operations do not engage in “electroplating,” EPA entered into an XL project with IBM at its Essex Junction site wherein EPA made statements suggesting that semiconductor manufacturing operations do involve “electroplating” and do have the potential to generate a listed hazardous waste.1 65 Fed. Reg. 54955 (Sept. 12, 20 00). Moreover, prior EPA guidance suggests that regulated listed hazardous waste can b e generated from the electroplating wastewaters no matter how much the wastewater has been treated. According to a memorandum from M. Straus to C. Jenkins, dated March 20, 1985, treatment may involve “several treatment steps for wastewaters, i n series, without any indication in[sic] of the Agency’s belief that at some point, the wastewater is ‘treated’ where it no longer is capable of generating the wastewater treatment sludge described in the listing.  It may even be that RCRA regulated sludge s can be generated after the point of discharge (except for the current exemption of POTW sludges).” Such an interpretation i s overly conservative and prevents the proper reuse of effluent. Legitimate reuse of electroplating wastewaters should be allowed w ithout the burden of having to manage any sludges generated as a listed hazardous waste. EIA requests that EPA clarify that treated electroplating wastewaters that are reused on - site in accordance with the legitimate recycling guidance are exempt from the definition of “solid waste.” Any residues from the reuse would be evaluated on their own merits, without regard to where they were derived from. Stakeholder: State of New York Topic: RCRA Hazardous Waste Minimization Program Enhancements **Comment: RCRA Hazardous Waste Minimization Program Enhancements.**  Even though Congress required generators to establish a Waste Minimization Program in the 1 984 amendments to RCRA, the only specific requirement for a facility for this program which has been implemented is that the generator must certify on its manifests that: “(1) the generator of the hazardous waste has a program in place to reduce the volume or quantity and toxicity of such waste to the degree determined by the generator to be e conomically practicable;” and “(2) the proposed method of treatment, sto rage, or disposal is that practicable method currently available to the generator which minimizes the present and future threat to human health and the environment” (42 USCA Sectio n 6922 (b)). These minimal requirements currently provide little, if any, r eal incentives for true waste m inimization. In order to actually encourage more waste minimization USEPA should consider regulations that focus on large
- quantity generators and, at a minimum, would provide a model facility’s wasteminimization program (WM P). The regulations would require that the facility retain documentation of its program and, most importantly, data on actual

reductions of waste being achieved. This documentation should be available for review as part of a RCRA inspection. Also, to be t ruly effective, there is a need for the WMP to be updated biannually. New York State’s Hazardous Waste Reduction Planning Pro gram could help act as a model for such a system. In addition, an Environmental Management System such as that required in USEPA’s Performance Track Program could be considered an acceptable substitute for a WMP as long as performance data on waste reductions was still tracked. Gen erators that achieved certain reported levels of reductions could possibly qualify for USEPA Performance Track or State environmental leadership program benefits. This would help provide a positive incentive for them to reduce waste and track the data. While generators other than large
- quantity generators may not be required to plan and report, doing so volun tarily could enable them to qualify for benefits as well. Facilities that do not have a WMP could be subject to enforcement. Facilities that have a WMP in place will benefit by realizing cost savings from reduced amounts of hazardous was tes generated throu gh reduced fees, paperwork, handling, disposal and transportation costs. Stakeholder: State of Texas Topic: Allow NEPT members to consider by
- products as co
- products under specified conditions and when the management of the material can be shown to be as protective of the environment Comment: The TCEQ suggests that EPA could encourage NEPT participation by allowing NEPT members to consider by
- products as co
- products under specified conditions and when the management of the material can be shown to be as protective of the environment. This incentive could encourage participation in NEPT and assure the highest use of materials. Many materials are currently disposed of or incinerated rather than reused since by
- products are still defined as solid waste, t hus “tainting” the material from many valid reuse options. As an example, 40 CFR 261.2(a), Table 1, classifies many by
- product streams as solid waste and subjects them to RCRA requirements. Many organizations do not recover and reuse useful mat erials in "b y - product" classified streams where the rules make it easier (less costly and less burdensome) to send by
- product materials to off
- site incineration. Incineration should be the last resort since it contributes to greenhouse gas emissions and wastes energy rather than removing contaminants and reusing the material for energy recovery or a higher use. One concept is to provide an incentive to NEPT members that would allow them to consider material that was previously conside red a by
- product (e.g., solid was te) as co
- products provided the new process can be demonstrated to be “as protective” of the environment. Stakeholder: State of Texas Topic: Allow NEPT members to to burn material that was previously defined as by
- products (e.g., solid waste) for beneficial heat recovery provided the heat recovery process can be demonstrated to be as protective of the environment Comment: A second concept is to allow NEPT members the option to burn material that was previously defined as by
- products (e.g., s olid waste) for beneficial heat recovery provided the heat recovery process can be demonstrated to be as protective of the environment. U nder this option the process would be regulated under the Clean Air Act, Title V, and not under RCRA since the material would no longer be considered a solid waste. This would remove these materials from the boiler and industrial furnace (BIF) rules and encourage higher reuse, and lower fuel us age. This would also be a very appealing incentive and may drive higher levels o f NEPT membership (and associated performance) since the price of fuel is six times higher than when the RCRA rules were initially adopted. Stakeholder: State of Texas Topic: Allow more flexibility for recycling for NEPT members Comment: A third conc ept is to allow more flexibility for recycling for NEPT members. Specifically, currently a site that continuously recycles a material can exclude that material from the solid waste definition. An incentive would be to allow NEPT mem

bers to store materials that are recycled (on- site or offsite) for up to 90 days, and still takeadvantage of the exclusion from solid waste definition (currently restricted under § 261.2(c)(3) and associated Part

264, 265 and 270 regulations.) An additional incentive for NEPT m embers would be to exempt them from the requirement to certify a waste minimization program on manifests, since the NEPT program includes broader environmental improvement projects that are inclusive of waste minimization. Stakeholder: State of Texas Topic: I ncrease overall funding and/or allow states to reallocate federal funds to build additional capacity for state pollution prevention and environmental assistance programs under the Performance Partnership Grants (PPG). Comment: The TCEQ recommend s that EPA increase overall funding and/or allow states to reallocate federal funds to build additional capacity for state pollution prevention and environmental assistance programs under the Performance Partnership Grants (PPG). The TCEQ rec ommends that E PA review existing state pollution prevention legislation as a potential model for EPA to require LQG pollution prevention plann ing to replace the existing “certification in place” requirement under RCRA. States have documented that hazardous waste generat ors which do not prepare pollution prevention plans often generate increased amounts of hazardous waste and increased environmental costs. Stakeholder: State of Texas Topic: Continue to develop performance
- based metrics to report overall source reducti on and waste minimization results reported by the regulated community Comment: The TCEQ recommends that EPA continue to develop performance
- based metrics to report overall source reduction and waste minimization results reported by the regulated communi ty.
Stakeholder: State of Texas Topic: Prioritize pollution prevention programs to target reductions of persistent, bioaccumulative, and toxics (PBTs) to reduce impacts on human health and the environment Comment: The TCEQ recommends that EPA prioritize pollution prevention programs to target reductions of p ersistent, bioaccumulative, and toxics (PBTs) to reduce impacts on human health and the environment. The TCEQ recommends that EPA consider alignment of the existing and future Resource Conservation Challenge (RCC) programs, such as the National Waste Minimization Partnership, with existing state programs to promote a more coordinated effort which provides recognition at the state and federal level. Stakeholder: State of Texas Topic: Consider using RCC programs to s erve as an “on ram p” to the NEPT Comment: The TCEQ recommends that EPA also consider using RCC programs to s erve as an “on ramp” to the NEPT. Burden reductions and pollution prevention/recycling benefits could be achieve d through additional By
- Product Synergy education. The difficulty is in placing this effort into a reasonable and reliable performance measure. Stakeholder: Department of Energy (DOE) Topic: Recommendations for encouraging generators to practice source reduction and recycling practices:Comment: DOE suggests the following possible ways for the EPA to encourage generators to practice source reduction and recycling pract ices:

 Provide informational tools, such as public education and sustainability labeling.

 Adopt new regulatory strategies, such as extended product responsibility requirements.

 Work with industry to provide more environmentally benign chemical substitutes.

 Work with chemical manufacturers to review the shelf life limitatio n of chemicals, establish unbiased shelf
- life data, and encourage generators to extend the shelf life of chemicals based on reliable scientific data.

 Provide more pollution prevention literature targeted to specific industries, and consolidate the EPA websites that deal with pollution prevention into a central clearinghouse website. Stakeholder: Alliance of Automobile Manufacturers Topic: REMOVE WASTE MINIMIZATION CERTIFICATION REQUIREMENTS FROM THE MANIFEST

Comment: E PA SHOULD REMOVE WASTE MINIMIZATION CERTIFICATION REQUIREMENTS FROM THE MANIFEST

### . EPA should remove the generator’s waste minimization certification statement from the hazardous waste manifest. The Biennial Report requires: • A description of the efforts taken during the year to reduce the volume and toxicity of waste generated. (40 CFR 262.41 (a)(6)), and • A description of the changes in volume and toxicity of waste actually achieved during the year in comparison to previous ye ars to the extent such information is available for years prior to 1984. (40 CFR 262.41(a)(7)). Requiring a certification on the manifest does not reflect the reality of plant operations. Hazardous waste minimization prog rams are invariably plant
-wide and often corporate in scope. Hazardous waste manifests, in contrast, relate to a single, discrete event involving a single, discrete waste. The person responsible for signing the manifest is almost never at a level where decisions regarding waste minimizations are made . Having such a person certify t herefore is not reflective of actual practice. Rather, the certification required on the Biennial Report is a better guarante e that such programs are in place because the reports are generated by these who have responsibility for their content and the practices that flow from it. 

### 16 commenters; 28 comments