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

I attended training from another provider and learned absolutely nothing. Lion is much better. Hands down.

Nicole Eby

Environmental Specialist

Convenient; I can train when I want, where I want.

Barry Cook

Hazmat Shipping Professional

More thorough than a class I attended last year through another company.

Troy Yonkers

HSES Representative

This course went above my expectations from the moment I walked in the door. The instructor led us through two days packed with useful compliance information.

Rachel Stewart

Environmental Manager

Lion's information is very thorough and accurate. Presenter was very good.

Melissa Little

Regulatory Manager

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

Michael Britt

Supply Chain Director

The workshop covered a lot of information without being too overwhelming. Lion is much better, more comprehensive than other training providers.

George Alva

Manufacturing Manager

Lion's course was superior to others I have taken in the past. Very clear in the presentation and the examples helped to explain the content presented.

George Bersik

Hazardous Waste Professional

I think LION does an excellent job of any training they do. Materials provided are very useful to my day-to-day work activities.

Pamela Embody

EHS Specialist

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

Kevin Pylka

Permitting, Compliance & Environmental Manager

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.