From: Matt Kaarlela (email@example.com)
Date:Wed, 28 Feb 2001 15:31:54 -0800
Even if the waste ink is hazardous there might be another way to exclude it from counting towards generator status. I've been working on it for the past 5 months and just recently got the formal letter from the TNRCC authorizing Texas printers (meeting conditions stated in the letter) to reclassify and manage waste ink that would otherwise be considered a hazardous waste as a "paint and paint related" universal waste. Reclassifying waste ink as a universal waste has some significant benefits to printers in Texas. A couple of the major benefits are increasing the amount of time waste ink can be accumulated on site and potentially lowering the printer's generator status by removing a major hazardous waste stream. We are finding many printers can drop from large quantity generator to small quantity generator or from small quantity generator to conditionally exempt small quantity generator simply by reclassifying their waste ink as a universal waste. I would encourage other associations to look into similar changes for their state.