ACA Urges Missouri Department of Natural Resources to Adopt Universal Waste Standards for Paint
February 27, 2018 •
Last week, ACA submitted comments to the Missouri Department of Natural Resources (Missouri DNR), suggesting that the agency expand its standards for universal waste management to include paint and paint-related wastes (PPRW). Missouri DNR has published proposed changes to its hazardous waste regulations, as part of the Red Tape Reduction review process.
Because ACA member companies operate over 40 facilities in Missouri, ACA believes the review of the standards should include an examination of PPRW.
In its comments, ACA noted the Ohio Environmental Protection Agency’s (EPA) December 2017 adoption of universal waste rules allowing hazardous non-empty aerosol containers, hazardous antifreeze, and hazardous paint and hazardous paint-related wastes to be classified and managed as universal waste. ACA had urged that classification to facilitate and promote proper handling, recycling, and disposal of hazardous waste throughout the state.
PPRW as universal waste has also been adopted in Texas — Managing Paint and Paint-Related Waste Under the Universal Waste Rule — and New Jersey allows used oil-based finishes to be managed as universal waste. ACA underscored these successful examples for the state addition of PPRW to its universal waste program (i.e. meeting the requirements of federal regulations, 40 CFR Part 273 Subpart G —Petitions to Include Other Wastes Under 40 CFR Part 273), and believes Missouri DNR could therefore accomplish both objectives of creating environmental benefits as well as promoting the competitiveness of Missouri businesses.
ACA also offered to engage in the stakeholder process Missouri DNR has opened. Specifically, ACA offered to provide input regarding:
- the environmental benefits that would result from classifying PPRW as universal waste;
- how classifying PPRW as universal waste would create better facility management; and
- specific examples of why classifying PPRW as universal waste would alleviate regulatory burdens, costs, and encourage more recycling and reuse.
ACA also directed Missouri DNR to Ohio EPA’s guidance on Ohio Specific Universal Waste as a resource.