Treatment is defined as any method, technique, or process, including neutralization, designed to change the physical, chemical, or biological character or composition of any hazardous waste so as to neutralize such waste, or so as to recover energy or material resources from the waste, or so as to render such waste non-hazardous, or less hazardous; safer to transport, store, or dispose of; or amenable for recovery, amenable for storage, or reduced in volume (40 CFR §260.10).
The following guidance documents provide additional clarification on the crushing of hazardous waste containers and whether or not such activity constitutes treatment:
Memo, Petruska to Citizen; September 12, 1989 (RCRA Online #311466)
Memo, Skinner to Scarbrough; April 26, 1984 (RCRA Online #12214)
These guidance documents are available in the RCRA Online database at the following URL: http://www.epa.gov/rcraonline/
In addition, it is important to note that this guidance represents clarification of the Federal regulations. Most states are authorized to implement the Federal regulations. We recommend that you also contact your state's implementing agency to acquire additional information on crushing hazardous waste containers and hazardous waste treatment. The Office of Resource Conservation and Recovery (ORCR) has compiled a complete list of waste program Web sites maintained by EPA Regional offices and state environmental agencies to help users locate the appropriate agency within their states.
Is crushing a hazardous waste container regulated as hazardous waste treatment?
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