IPMI ERAC Active on Several Fronts

摘要

The IPMI Environmental & Regulatory Affairs Committee (ERAC) continues to be actively engaged in several developments, most environmental but at least one which is not, of significant interest to our members. In the area of broadest interest, the US Environmental Protection Agency has recently announced that it will again change its definition of waste, i.e. its description of the types of materials which it regulates under the Resource Conservation and Recovery Act (RCRA), an intensive environmental program. This fundamental definition, which determines what is included in the RCRA program and that is not, has been a problem for the Agency and for regulated companies for many years, and the EPA hopes to finally provide a clear and rational definition. This may be a promising development, because the EPA has recently been promoting recycling as a non-waste, non-RCRA regulated activity. It recently issued new regulations which provide that secondary metal-bearing materials produced by mines, even if hazardous, are not waste when they are treated as valuable raw materials, i.e. stored properly and reclaimed promptly. That precedent, if followed for other precious metal-bearing materials, may result in less federal regulation of our industry. Te IPMI already has a petition pending before the EPA seeking a ruling that our prepared sweeps material is not a waste, and the EPA may decide that petition as part of its proposal. IPMI ERAC Chair John Bullock has spoken to Elizabeth Cotsworth, Director of the EPA RCRA Program, and Ingrid Rosencrantz, who is leading the definition effort for EPA, with regard to our industry materials. Further information will continue to be provided to EPA through ERAC.