The Definition of Solid Waste (DSW) is extremely important and relevant to the industry. DSW is the basis for RCRA regulations, and RCRA has the potential to regulate inbound material that members purchase for feedstock (e.g., unprocessed scrap), recycling processes, and manufactured products (e.g., specification-grade scrap commodities). Materials outside DSW are unregulated and may move freely.
On July 13, 2015, a new set of regulations comes into effect defining what is “legitimate” recycling and therefore not regulated under the hazardous waste provisions of the Resource Conservation and Recovery Act (RCRA), all as part of EPA’s new “definition of solid waste” (DSW) rule.
ISRI has created a compliance guidance document for members to assist in documenting that you are a legitimate recycler of scrap metal. In addition, please find further helpful resources from the EPA and other sources.