Definition of Solid Waste (DSW) Rule

In October of 2008, the US Environmental Protection Agency (EPA) signed a revised Definition of Solid Waste (DSW) rule after over a decade of IPC lobbying efforts. By removing regulatory barriers that inhibit the recycling of manufacturing wastes, the DSW rule has the potential to save industry including electronics manufacturers approximately $95 million dollars per year while simultaneously providing an environmental benefit by reducing waste. However, in January of 2009, the Sierra Club filed a petition for reconsideration, which could result in EPA reopening the entire rule. If the rule is reopened, the decades of effort put into finalizing the DSW rule by both EPA staff and industry could be transformed into a colossal waste of time, effort, and money.

The EPA held a public meeting on June 30, 2009 to hear comments from a variety of stakeholders on whether to reopen the rule. IPC testified at this public meeting and submitted comments to the EPA discouraging EPA from adhering to the Sierra Club’s request and reopening the DSW rule. If the EPA decides to reopen the DSW rule, it may mean the tedious hazardous waste regulations that were removed in the final rule are reinstated.

The EPA has come forward and determined that an environmental justice study is needed to determine whether the DSW rule is beneficial to low-income and minority populations. On January 15, 2010, the EPA released a draft scope and methodology for an environmental justice study. The EPA will hold two public meetings and an online roundtable to hear input from the general public and other stakeholders. Please visit EPA’s website for more information and how you can get involved.

• IPC Testifies at EPA Public Meeting on DSW Rule
• IPC Testifies at EPA Public Meeting on DSW Rule (video)
• IPC Testimony for June 30, 2009 EPA Public Meeting on DSW (written comments)
• Background Information on the Definition of Solid Waste
• IPC Advocacy
• IPC’s Lobbying for New Definition of Solid Waste Rule Wins Big
• Letter to the States (.pdf) (Members Only)
• IPC Memo on 2007 DSW Reproposal (.pdf)
• IPC Comments on EPA’s Revisions to the DSW – 2004 (.pdf)
• EPA’s DSW Website

Electroplating Sludge (F006)

• IPC Submits Letter to OSWER on Reintroducing the F006 Rule (.pdf) (January 2010)
• EPA Withdraws Draft F006 Sludge Proposal (May 2006)
• F006-F008 Metals Reclamation Rule (October 2005)
  Jim O’Leary, Senior Program Analyst, offers an overview of EPA’s plans for the rulemaking