← American Chemistry Council
EPARulemakingEPA-HQ-OLEM-2023-0320

Used Drum Management and Reconditioning

RIN
—
Last modified
Aug 26, 2024
Comment window
closed 979d ago
American Chemistry Council filings
1

Activity

American Chemistry Council filed 1 comment on this docket between Nov 28, 2023 and Nov 28, 2023. 27 other organizations filed here. The comment window closed 979d ago.

What American Chemistry Council filed (1)

Nov 28, 2023· Comment submitted by American Chemistry Council (ACC)· EPA-HQ-OLEM-2023-0320-0081

ACC appreciates the opportunity to provide the following comments to the U.S. Environmental Protection Agency on its proposed Used Drum Management and Reconditioning Advance Notice of Proposed Rulemaking. ACC appreciates EPA's recognition that this ANPRM does not represent a proposal and as such, will not directly result in regulatory changes without adequate supporting analyses and proper notice-and-comment opportunities. ACC member companies are regulated under the Resource Conservation and Recovery Act and engaged in the generation and management of used drums, including the treatment, storage, or transportation of these containers under applicable regulatory requirements addressing hazardous waste management at the state and federal levels. Our member company facilities are potentially affected parties by the actions outlined in ANPRM and as such, offer the following recommendations for EPA's consideration.

Download attachment ↓View on regulations.gov →

Abstract

In response to growing concerns about environmental and public health issues at drum reconditioning sites, EPA is publishing an Advance Notice of Proposed Rulemaking (ANPRM) on the drum reconditioning industry. The purpose of the ANPRM is to engage stakeholders early in the process. EPA is hoping to obtain additional information on the industry as a whole, including waste management practices and more information about damage cases and their impact to nearby communities. The ANPRM will also provide an opportunity for stakeholders to comment on a range of potential ways of addressing these problems, including potential future regulatory changes, as well as suggest other alternatives for EPA to pursue in future rulemakings.

View on regulations.gov →

Co-filers (27)

See everyone who commented →