EPA Issues Major Reinterpretation on Excluded PCB Products
Author:
Jim Okun
Date Published:
4/2013
Description:
In a regulatory reinterpretation with far significant implications, the USEPA clarified the definition of “Excluded PCB Products” as used in the PCB regulations and signaled its intention to deemphasize the regulation of low concentration PCBs in commercial products. Excluded PCB products are defined as commercial products containing PCBs originating from Aroclor or non-Aroclor sources where the PCBs are present at less than 50 ppm.
The excluded product reinterpretation was the result of a request by the Institute of Scrap and Recycling
Industries, Inc. (ISRI) which was seeking clarification on the management of plastic residue from automobile shredding and recycling. This plastic residue sometimes contains low levels (less than 50 ppm) PCBs. Managing the material as a PCB remediation waste limited the recycling industry’s ability to reuse this plastic and increased the cost of the recycling operations. If it was clearly understood to be an excluded product, then the regulatory burden would be less.
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