Earlier this month Ohio EPA proposed to amend its rules regarding the identification and listing of hazardous wastes under the Ohio Administrative Code. The proposed rule seeks to regulate, and provide a conditional exclusion for “hazardous waste textiles.”
The proposed rules define “hazardous waste textiles” to include any material that comes into contact with a hazardous waste as defined by Ohio law; Ohio EPA’s examples of “hazardous waste textiles” include rags, gloves, uniforms, linens, smocks, coveralls and mops, among other materials.
Under the proposed rules, the 10-step procedure for an entity to follow in order to have a contaminated textile excluded from regulation is clear, but the rule is very strict to meet, which raises some concern regarding the regulatory burden and compliance costs that will be associated with this new rule.
OMA environment counsel Frank Merrill of Bricker & Eckler drafted this memo detailing the changes and procedures. If you have any questions regarding the proposed exclusion, how to meet the exclusion, or what impact the proposed rules will have if enacted, contact OMA’s Rob Brundrett . 1/25/2018