DCHAS-L Discussion List Archive

From: "Margaret Rakas" 
Date: March 19, 2009 2:04:15 PM EDT
Subject: Re: [DCHAS-L] Procuring Acetonitrile

Also it's a good idea to check with your state authority charged w/ 
implementing RCRA.  As of a few years ago (last time I checked) my  
understanding was that our state had more stringent rules about  
distilling waste solvent for recycling purposes than RCRA, in terms of  
recordkeeping and other requirements.  At that time, it was definitely  
not a matter of "oh, just go ahead and do it...", at least according  
to a presentation I attended which featured EH&S folks from one of the  
bigger universities in Boston (I don't remember which one).

So your state's requirements or "take on this" might be the same as  
those of Federal RCRA, or more stringent, but would also be a factor  
in this activity...

The above is my personal opinion only, not legal or business advice  
and may not be the opinion of my employer or any group to which I  
belong..
Margaret Rakas