EPA ANPRM on Used Drum Management and Reconditioning

Background

On August 11, 2023, EPA announced an advanced notice of proposed rulemaking (ANPRM) on used drum management and reconditioning. More specifically, EPA is soliciting for information and requesting comments to assist in developing regulatory and/or non-regulatory options that would ensure the proper management of used industrial containers that held hazardous chemicals or hazardous waste. This ANPRM does not propose any regulatory requirements of changes to any existing regulatory requirements.

Through this ANPRM, EPA is evaluating and seeking input on the generation, transportation, and management of used containers, some of which may not be empty enough as allowed under the Resource Conservation and Recovery Act (RCRA), to assess the extent to which any future actions could reduce the risk to human health and the environment from all sources during the lifecycle of used containers.

ACA Staff is working through the Transport Committee and the Environmental Management Committee to gather input and comments from its members on the potential impact to the coatings industry. ACA Staff is also working with a coalition of associations being led by the Reusable Industrial Packaging Association (RIPA). ACA submitted a comment letter to EPA in November 2023.

ACA Staff

Suzanne Chang
Counsel