Search

Precious Metals Recycling

Posted on 10/23/2012 by James Griffin

Hazardous wastes that contain economically significant amounts of precious metals are excluded from RCRA when reclaimed, regardless of their other properties. A few rules still apply. They can be found at 40 CFR 266, Subpart F.
 
The U.S. EPA considers the following materials to be “precious metals”: gold, silver, platinum, palladium, iridium, osmium, rhodium, and ruthenium.
 
While not explicitly stated in 40 CFR 266, Subpart F, the U.S. EPA considers the following features to characterize the legitimate recovery of precious metals:
 
  • Economically significant amounts of precious metals
  • Efficient recovery operations
  • No land disposal of wastes destined for recovery
  • Payment by the reclaimer to the waste generator
  • Net financial return to the generator (i.e., sufficient to cover all costs)
The absence of any one of these properties may indicate that the recovery is not a legitimate recycling activity and consequently, the wastes would be subject to full regulation as hazardous waste. Under 40 CFR 261.2(f), any person claiming an exclusion from RCRA has the full burden of proving that his or her activities are legitimate. If there is any controversy, the applicable regional and State waste management authorities will determine which activities are legitimate, or not, on a case-by-case basis.
 
These criteria were first outlined by the U.S. EPA in the Federal Register (January 4, 1985; 50 FR 648-649) when this exclusion was first created and further explicated in a 1998 letter from Elizabeth A. Cotsworth (then Acting Director EPA Office of Solid Waste) to the Law Offices of David J. Lennett.
 
If generators qualify for the precious metals recycling exclusion, they must:
 
  1. Notify the EPA of their hazardous waste activities;
  2. Follow the manifesting requirements of 40 CFR 262, Subpart B; and
  3. Keep records to prove they are not speculatively accumulating the material by taking inventory on January 1st and shipping at least 75% by weight or volume off premises to the reclamation facility by December 31st of the same year.
Generators are not required to store this material in RCRA-regulated management units.
 
What other RCRA exclusions do you find useful? Share below.
 
Capitalize on the exclusions that apply to your operations! At Lion’s Advanced Hazardous Waste Management Workshop, you’ll learn practical strategies to streamline your operations, cut costs, and minimize waste, and meet the EPA’s annual training requirement for hazardous waste personnel.

Tags: hazardous, RCRA, recycling, waste

Find a Post

Compliance Archives

Lion - Quotes

Course instructor was better prepared and presented better than other trainers. Course manual and references were easier to use as well.

Marty Brownfield

Hazardous Waste Professional

I like the consistency of Lion workshops. The materials are well put together and instructors are top notch!

Kevin Pylka

Permitting, Compliance & Environmental Manager

I can take what I learned in this workshop and apply it to everyday work and relate it to my activities.

Shane Hersh

Materials Handler

The instructor clearly enjoys his job and transmits that enthusiasm. He made a dry subject very interesting and fun.

Teresa Arellanes

EHS Manager

I tried other environmental training providers, but they were all sub-standard compared to Lion. I will not stray from Lion again!

Sara Sills

Environmental Specialist

Lion was very responsive to my initial questions and the website was user friendly.

Michael Britt

Supply Chain Director

The training was impressive. I am not a fan of online training but this was put together very well. I would recommend Lion to others.

Donnie James

Quality Manager

The instructor did an excellent job presenting a very dry subject; keeping everyone interested and making it enjoyable.

Marc Bugg

Hazardous Waste Professional

The instructor kept the class engaged and made learning fun. There was a lot of information to cover but time flew by. I will definitely use Lion in the future!

Chelsea Minguela

Hazmat Shipping Professional

Lion courses always set the bar for content, reference, and practical application. Membership and access to the experts is an added bonus.

John Brown, CSP

Director of Safety & Env Affairs

Download Our Latest Whitepaper

Find out what makes DOT hazmat training mandatory for employees who sign the hazardous waste manifest, a “dually regulated” document for tracking shipments.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.