The U.S. EPA Draft Guide for Industrial Waste Management—Too Little, Too Late?
December 1999
Citation:
29
ELR 10764
Issue
12
Editors' Summary: EPA recently proposed for public comment a draft guidance document that discusses voluntary federal recommendations for hundreds of thousands of nonhazardous industrial waste sites that currently escape RCRA regulation. In this Dialogue, a member of the chartered advisory group that assisted the Agency in the development of the document discusses its attributes and shortcomings. The Dialogue describes the history of EPA's use of RCRA Subtitle D and the statutory and programmatic obstacles to meaningful federal regulation. It then outlines the draft Guidance and concludes that EPA's effort falls short of the important goal of assessing and addressing the risks presented by industrial waste disposal facilities.
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