letter-to-lisa-jackson-on-definition-of-solid-waste-rule-9b9e1737914aca4e.pdf

A coalition of environmental and health organizations argues that the EPA's 2008 rule exempting recycled hazardous waste from RCRA regulation creates significant public health risks, particularly for minority and low-income communities, and allows for the unsafe incorporation of toxins into commercial products, including those for children.

• The 2008 "Revisions to the Definition of Solid Waste" rule removes hazardous wastes destined for recycling from the definition of "solid waste," meaning facilities claiming to recycle these wastes are no longer required to follow RCRA safe-handling and reporting requirements.
• EPA data indicates that RCRA permitting is essential for preventing contamination; of 218 identified "damage cases" involving toxic releases from recycling, 209 occurred at facilities not operating under RCRA permits.
• The rule disproportionately impacts minority and low-income communities, who form the majority (59 percent on average) of populations in neighborhoods surrounding hazardous waste facilities, yet the EPA failed to evaluate these impacts during rule-making in violation of Executive Order 12,898.
• The rule allows hazardous waste to be incorporated into commercial products, including those for children, even if the resulting product is more toxic than similar market alternatives, and permits manufacturers to decide if RCRA should apply.

APA

Earthjustice (2009). letter-to-lisa-jackson-on-definition-of-solid-waste-rule-9b9e1737914aca4e.pdf. https://earthjustice.org/wp-content/uploads/letter-to-lisa-jackson-on-definition-of-solid-waste-rule.pdf

Chicago

Earthjustice. letter-to-lisa-jackson-on-definition-of-solid-waste-rule-9b9e1737914aca4e.pdf. 2009. https://earthjustice.org/wp-content/uploads/letter-to-lisa-jackson-on-definition-of-solid-waste-rule.pdf.

Wikipedia

{{cite press release |author=Earthjustice |title=letter-to-lisa-jackson-on-definition-of-solid-waste-rule-9b9e1737914aca4e.pdf |date=20 April 2009 |url=https://earthjustice.org/wp-content/uploads/letter-to-lisa-jackson-on-definition-of-solid-waste-rule.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{earthjustice2009lettertolisajacksonondefinitionofsolidwasterule9b9e1737914aca4epdf, author = {{Earthjustice}}, title = {{letter-to-lisa-jackson-on-definition-of-solid-waste-rule-9b9e1737914aca4e.pdf}}, publisher = {Earthjustice}, year = {2009}, month = apr, url = {https://earthjustice.org/wp-content/uploads/letter-to-lisa-jackson-on-definition-of-solid-waste-rule.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }