How does PBMS affect SW-846?
Due to the complexities in material and waste characterization in support of RCRA, SW-846 functions under the Performance Based Approach (PBMS), and flexibility (in choosing sampling and analytical approaches to meet measurement requirements) is allowed when it is appropriate to do so. PBMS conveys "what" needs to be accomplished, but not prescriptively "how" to do it. EPA defines PBMS as a set of processes wherein the data needs, mandates, or limitations of a program or project are specified, and serve as criteria for selecting appropriate methods to meet those needs in a cost-effective manner. The criteria may be published in regulations, technical guidance documents, permits, work plans, or enforcement orders. Under a performance-based approach, EPA would specify:
- Questions to be answered by monitoring.
- Decisions to be supported by the data.
- Level of uncertainty acceptable for making decisions.
- Documentation to be generated to support this approach in the RCRA monitoring program.