EPA’s Definition of Solid Waste (DSW) Rule, which the U.S. Environmental Protection Agency (EPA) finalized in December 2014 and which went into effect in July 2015, is complicated. While a lot of focus has been on the DSW Rule’s revised “generator-controlled exclusion” and two new exclusions—the “verified recycler” exclusion and the “remanufacturing of solvents” exclusion—in reality, it is three definitions that are at the heart of the Rule. Understanding these definitions is key to successfully utilizing the three conditional exclusions and essential to DSW Rule compliance.
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The DSW Rule defines “contained” in order to prevent mismanagement of hazardous secondary materials (HSMs) during storage. The new definition specifies that storage units must be in good condition, properly labeled, not hold incompatible materials, and address potential risks of fires or explosions.