Truckers and collectors are registered as federal and state hazardous waste transporters. Fuel blend points, broker collection and transfer locations, solvent recycling facilities, and fuel blend facilities at cement plants all have either notified EPA of their activities associated with waste fuels or are registered hazardous waste management facilities. The combustion portion of waste fuel activity on the part of the cement plant currently fits within the jurisdiction of the plant's Clean Air Act permits rather than RCRA hazardous waste management regulations. EPA's pending concept is to regulate hazardous incinerators and the burning of hazardous waste fuels in furnaces and industrial boilers on an approximately equivalent basis. Other miscellaneous cement plant waste fuel streams such as wood chips, used tires, rice hulls, and filter cake generally fit within a state's solid waste management regulations.
Some materials can be state regulated special wastes or industrial wastes.
In some cases the materials can be U. S. Department of Transportation hazardous materials during transportation. A considerable waste oil volume already moves through the hazardous waste fuel system, with the used oil collection and transport activities regulated in some states as special waste operations. EPA's first ruling on adding waste oil to the regulated universe under RCRA was that the net impact on the environment would be worse rather than better. The court challenge resolved that EPA had to make its waste oil management evaluation strictly on technical or scientific factors and not social issues. Congress may end up making this decision via the RCRA reauthorization legislative process.