I used this exact argument in my defense (as suggested by the manufacturer of my recycler) and the EPA responded with the following:
"You should consider discussing your recycling activity with MassDEP (the state agency). Every state has unique interpretations on when a recycling license or permit is required--and the manufacturer of a device is not the best contact to make that decision". Jim _______________________ James E. Staruk HT(ASCP) www.masshistology.com www.nehorselabs.com -----Original Message----- From: James Watson [mailto:[email protected]] Sent: Thursday, June 26, 2014 2:19 PM To: 'Mass Histology'; [email protected] Subject: RE: [Histonet] RE: Recycle or not? This topic was discussed at a meeting somewhere that I attended and here with our safety staff. The work around that we do here to conform to waste disposal regulations here in Ca. is that xylene for recycling is not classified as waste, so it does not enter the waste stream. Since you are not recycling waste you are not practicing "waste management". James Watson HT ASCP GNF Genomics Institute of the Novartis Research Foundation Tel 858-332-4647 Fax 858-812-1915 [email protected] -----Original Message----- From: [email protected] [mailto:[email protected]] On Behalf Of Mass Histology Sent: Thursday, June 26, 2014 9:29 AM To: [email protected] Subject: [Histonet] RE: Recycle or not? This might be a little off the topic: We recently had the enjoyment of undergoing a day-long EPA inspection and we were issued a warning of "practicing waste management without proper permits" when they saw our recycler. Has anyone else ever been hassled by the EPA regarding this? Jim _______________________ James E. Staruk HT(ASCP) www.masshistology.com www.nehorselabs.com _______________________________________________ Histonet mailing list [email protected] http://lists.utsouthwestern.edu/mailman/listinfo/histonet
