EPA is beginning to put together regulatory and guidance strategies for retailers covering a broad range of issues such as hazardous waste management, disposal of aerosol cans, etc.  This month, the Agency has released the, “Strategy for Addressing the Retail Sector under RCRA’s Regulatory Framework.” I’ve attached a recent blog by an EPA Administrator regarding this matter that contains a link to their strategy for RCRA compliance for the retail industry.

According to EPA, the retail sector handles a large number of diverse products (for example, one retailer has reported about a million products and 4,000 facilities nationwide), many of which may potentially become regulated as hazardous waste under RCRA when discarded.  EPA also states that retailers are required to make numerous hazardous waste determinations at thousands of sites, generally by store employees with limited experience with the RCRA hazardous waste regulations.  EPA is also interested in how the “reverse distribution” process might be regulated.