HSM Inspector Checklist Tool for Facilities Generating and Recycling Hazardous Secondary Materials (2024 Version)
This document is a series of checklists that is designed to assist EPA and state implementing agencies with monitoring compliance at facilities that are generating and recycling hazardous secondary materials under the Resource Conservation and Recovery Act hazardous waste regulations. This document describes and summarizes statutory provisions, regulatory requirements, and policies. It is not a substitute for these provisions, regulations, or policies, nor is it a regulation itself.
Industrial facilities generating and recycling hazardous secondary materials and the general public can also use this document to locate resources addressing specific regulatory issues related to recycling hazardous secondary materials. The document includes an initial checklist that serves as the starting point when looking at a facility generating and/or recycling hazardous secondary materials and a series of appendices that address related issues, such as whether the recycling is legitimate, whether the hazardous secondary materials are being speculatively accumulated, the type of recycling being performed, and whether a recycling exclusion or exemption is applicable.