Frequent Questions

What is a spent material and what is its regulatory status when reclaimed?

A spent material is any material that has been used and, as a result of contamination, can no longer serve the purpose for which it was produced without undergoing regeneration, reclamation, or reprocessing (§261.1(c)(1)). Examples of spent materials include spent solvents, spent activated carbon, spent catalysts, and spent acids (50 FR 614, 624; January 4, 1985). The regulatory status of a secondary material when reclaimed depends on the type of materials reclaimed. Spent materials are solid wastes when they are reclaimed. Spent materials are also regulated as solid wastes when used in a manner constituting disposal; burned for energy recovery, used to produce a fuel, or contained in fuels; or accumulated speculatively (§261.2(c)). 

Additional guidance on spent materials is available in the following documents: 

Memo, Bussard to Woods; August 30, 1994 (RCRA Online #11868
Memo, Shapiro to Directors; March 24, 1994 (RCRA Online #11822
Memo, Shapiro to Davis; March 24, 1994 (RCRA Online #11821
Memo, Lowrance to Eschborn; July 16, 1990 (RCRA Online #11541
Monthly Call Center Report Question; December 1986 (RCRA Online #12790
Memo, Straus to Gowen; August 13, 1985 (RCRA Online #11101)

Have more questions? Submit a request