From: Dan Nowlan <dnowlan**At_Symbol_Here**BERRYMANPRODUCTS.COM>
Subject: Re: [DCHAS-L] Evolution of chemical law and toxicology...
Date: Tue, 21 May 2019 20:36:25 +0000
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: 96B01B2E9C84674ABE1BA48CDA33910303E7A7AAA9**At_Symbol_Here**BPMAIL.bpi.local

Ugh, I'm so bad at RCRA. IDK if it's truly that confusing or if I just try to get too "cute" drilling deep down into the classifications and confuse myself. If I have an immersion cleaner with methanol and/xylene that is spent (or, sometimes, maybe it's unspent), I struggle on how to classify. Is there easy-to-understand-guidance out there?
Sent via the Samsung Galaxy S7, an AT&T 4G LTE smartphone

-------- Original message --------
From: "Stuart, Ralph" <Ralph.Stuart**At_Symbol_Here**KEENE.EDU>
Date: 5/21/19 4:18 PM (GMT-05:00)
Subject: Re: [DCHAS-L] Evolution of chemical law and toxicology...

> Perhaps closer to what you are looking for can be found in the history of "hazardous waste."  As proposed in 1978, there were nine characteristics.  Just in time for the 1980 presidential season, the 'final' regulations with only four characteristic wastes -- D001, D002, D003, D004--D043.

This is a fascinating example, since it was designed to be as objective and technical as possible while balancing hazard information with available control technology at the time. However, neither the hazard information or the control technologies have remained the same over the last 40 years (EPA can't even agree with OSHA about what flammable means) and the RCRA system has a hard time keeping up with both types of changes, leading to some counter-intuitive interpretations. At the same time, RCRA has done a good job of establishing and supporting the development of a hazardous waste system in the US and the environment in general is much better off for it.

If you had time on your hands and wanted to focus on the evolution of RCRA over time, that would be a rich source of information on the nature and history of chemical regulation.

- Ralph

Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859


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