40 cfr 261.4(a)(14) - the shredded circuit board exclusion from regulation as a solid waste

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EXCLUSIONS FROM REGULATION AS SOLID WASTE One presentation in a series that briefly explains the Federal exclusions from full regulation for certain materials under the Resource Conservation and Recovery Act (RCRA). @DanielsTraining 1 40 CFR 261.4(a)(14) This presentation: 40 CFR 261.4(a)(14) : Shredded Circuit Boards

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US EPA regulations at 40 CFR 261.4 contain exclusions from many materials that might otherwise be regulated as a hazardous waste under the Resource Conservation and Recovery Act (RCRA). This presentation explains one of those exclusions.

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Page 1: 40 CFR 261.4(a)(14) - The Shredded Circuit Board Exclusion From Regulation as a Solid Waste

@DanielsTraining 1

EXCLUSIONS FROM REGULATION AS SOLID WASTEOne presentation in a series that briefly explains the Federal exclusions from full regulation for certain materials under the Resource Conservation and Recovery Act (RCRA).

40 CFR 261.4(a)(14)

This presentation: 40 CFR 261.4(a)(14): Shredded Circuit Boards

Page 2: 40 CFR 261.4(a)(14) - The Shredded Circuit Board Exclusion From Regulation as a Solid Waste

@DanielsTraining 2

PRESENTED BY:

Daniels Training Services815.821.1550www.DanielsTraining.comInfo@DanielsTraining.com

A different kind of training.

40 CFR 261.4(a)(14)

Page 3: 40 CFR 261.4(a)(14) - The Shredded Circuit Board Exclusion From Regulation as a Solid Waste

@DanielsTraining 3

40 CFR 261.4(a)

• Paragraph ‘a’ of section 261.4 identifies 25 materials excluded from regulation as a solid waste.

• If a material does not meet the definition of a solid waste, it cannot be a hazardous waste.

40 CFR 261.4(a)(14)

Solid Waste

Hazardous Waste

Page 4: 40 CFR 261.4(a)(14) - The Shredded Circuit Board Exclusion From Regulation as a Solid Waste

@DanielsTraining 4

The following materials are not solid wastes for the purpose of this part…”• Shredded circuit boards being recycled provided that they are:

1. Stored in containers sufficient to prevent a release to the environment prior to recovery; and,

2. Free of:• Mercury switches and relays.• Nickel-Cadmium and Lithium batteries.

40 CFR 261.4(a)(14)

Page 5: 40 CFR 261.4(a)(14) - The Shredded Circuit Board Exclusion From Regulation as a Solid Waste

@DanielsTraining 5

More to Consider…

• To use this exclusion, circuit boards must be destined for recycling, not disposal.

• Read this EPA interpretation for further guidance on the use of this exclusion.

• Check with your State as it may not recognize this Federal exclusion.

• Other exclusions may be suitable for circuit boards destined for recycling:

1. Recycled scrap metal @ 40 CFR 261.6(a)(3)(ii).

40 CFR 261.4(a)(14)

Page 6: 40 CFR 261.4(a)(14) - The Shredded Circuit Board Exclusion From Regulation as a Solid Waste

@DanielsTraining 6

40 CFR 261.4(a)(14) Verbatim:

(a) Materials which are not solid wastes. The following materials are not solid wastes for the purpose of this part:

(14) Shredded circuit boards being recycled provided that they are:

(i) Stored in containers sufficient to prevent a release to the environment prior to recovery; and

(ii) Free of mercury switches, mercury relays and nickel-cadmium batteries and lithium batteries.

40 CFR 261.4(a)(14)

Page 7: 40 CFR 261.4(a)(14) - The Shredded Circuit Board Exclusion From Regulation as a Solid Waste

@DanielsTraining 7

Got Questions About RCRA or HazMat Transportation?

I provide:

Annual RCRA Training for Hazardous Waste Personnel.

And

Triennial HazMat Employee Training.

Open enrollment or on-site.

Daniels Training Services815.821.1550Info@DanielsTraining.comwww.DanielsTraining.com

40 CFR 261.4(a)(14)