EPA Must Act on Petition to List PVC as Hazardous Waste

Posted on 5/9/2022 by Roger Marks

Per the terms of a proposed consent decree, US EPA must decide by January 20, 2023 whether to list discarded polyvinyl chloride (PVC) as a hazardous waste under the Resource Conservation and Recovery Act (RCRA) regulations.

An environmental group petitioned EPA to add PVC, vinyl chloride, and associated phthalate plasticizers to the universe of regulated wastes in 2014. EPA did not respond. In 2021, the environmental group filed a suit against EPA for failing to answer the petition in a timely fashion.  

The petition also requests that EPA regulate PVC under the Toxic Substances Control Act (TSCA), claiming that the material poses an "unreasonable risk" to human health and the environment. Section 6 of TSCA authorizes EPA to restrict the manufacture, import, production, and use of chemical substances that are determined to pose unreasonable risks. 

RCRA Petitions and the Law

Regulations found at 40 CFR 260.20 allow “any person” to petition EPA to add, remove, or modify environmental regulations related to hazardous waste.

The law requires EPA to respond to all petitions by soliciting public input, proposing a new rule, or denying the petition. EPA must respond to petitions “within a reasonable time” (42 USC 6974(a)).

What’s Hazardous About PVC?

Polyvinyl chloride (PVC) is one of the most widely produced synthetic plastic polymers in the world. PVC is used in construction for drainage pipes, drinking water pipes, roofing, flooring, and insulation of wires and cables. Other common uses for PVC include medical devices, packaging, and car interiors. 

The primary ingredient in PVC, vinyl chloride, is a flammable and toxic gas believed to contribute to the development of cancer, the petition says. PVC also contains chemical additives to make it stronger and more durable. The petitioners argue that these additives that can leach out after disposal, contaminate the environment, and potentially endanger the health of humans and animals.

The petition also states that discarded PVC contributes to the global problem of plastic pollution. In 2018, the world produced 44.3 million metric tons of PVC. Production is expected to increase to nearly 60 million metric tons by 2025. 

RCRA and RCRA Refresher Training—When and Where You Want

US EPA requires hazardous waste professionals to complete annual training on the RCRA requirements. Lion makes it easy to meet your RCRA training mandate in a variety of formats—nationwide public workshops, convenient online courses, live webinars, and on-site training.

Browse RCRA training options here to find the course that fits your needs, your schedule, and your learning style. 

Tags: environmental compliance, hazardous waste, PVC, PVC disposal, RCRA

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