Re[2]: disposal of "lead" protective aprons (as used in medi

["Ralph NORTH"<ralph.north@ccmail.adp.wisc.edu>]

The suggestion to let the Chemical Disposal people at your facility handle these
is a good one. But don't pack for prison quite yet. These may not be waste yet
if they're not discarded [see 40 CFR 261.2 (2)]. Even if they are discarded,
they may be excluded from regulation as solid waste. [See 40 CFR 261.4 (13)].

As Mr. Lipton implies, the Hazardous Waste Regulations are complicated and
should be navigated by knowledgeable staff. If there's no hazardous materials
managers on your staff, you may want to consider outside help.

My opinions only.

Ralph North


____________________Reply Separator____________________
Subject:    Re: disposal of "lead" protective aprons (as used in medical
Author: <radsafe@romulus.ehs.uiuc.edu >
Date:       3/25/99 6:32 AM

>You are the proud new owner of some RCRA hazardous
waste. 

..

>EPA fines are generally assessed on a per day of 
violation basis.  Now that I am making you aware of this, any violations
could 
be construed as willful, subjecting you to criminal penalties.  


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