In advocating for this proposed rule, ACA underscored to Ohio EPA 1) the environmental benefits that would result from classifying PPRW as universal waste; 2) how classifying PPRW as universal waste would create better facility management; and 3) provided specific examples of why classifying PPRW as universal waste will alleviate regulatory burdens, costs, and encourage more recycling and reuse.
ACA hopes this new regulation will serve as a model that can now be used to promulgate analogous regulations in other interested states. Currently, only Texas and New Jersey have universal waste rules for paint and paint-related waste.
ACA has long maintained that paint and paint-related waste satisfy the criteria for designating a new universal waste. Paint is used by a wide range of different manufacturing industries and establishments, and is not exclusive to a specific industry. Paint and paint-related waste does not pose a significant risk when accumulated and transported by manufacturers, establishments, and other users. ACA also stressed that designation as a universal waste will promote the proper recycling or disposal of the hazardous waste and divert it from non-hazardous waste management systems.
ACA has also noted that including both paint and paint-related waste is very important as certain materials are not incorporated into the actual product itself, but are nonetheless critical for paint application and should be listed a long with paint.
ACA will be submitting comments to Ohio EPA by the Dec. 21 comment deadline.
More information on Ohio's proposed Universal Waste Regulations is available here.
