Printech Archives, December 1997: Re: Unused inventory as Haz Waste?

Re: Unused inventory as Haz Waste?

Henry Boyter (
Thu, 15 Jan 1998 20:08:41 -0800

This is what RCRA people have always told me. There is a catch. Make sure that you do
not inadvertantly make that decision. The most common way it happens is someone puts a
label on a drum "waste oil" instead of "used oil" or "oil for recycling". The other is
when an inspector asks an employee what is in a drum and gets the reply that "... its old
material that the boss says we will never use and need to get rid of it someday.".

Henry Boyter, Jr., PhD


I was curious about the comment that unused inventory becomes waste after one year so I
called the RCRA hotline for clarification. According to the specialist, unused inventory
becomes a waste only at the time an owner/operator decides to discard it. That time marks
the point of generation and the beginning of accumulation. As long as no decision has been
made to discard the material, itıs not a waste.

Judy Zaczkowski



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