EPA guidance - HHW-type waste not exempt from non-household generators

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MAY 2, 1988

Honorable Tom Harkin
131 E. 4th Street
Room 314B
Davenport, Iowa 52801

Dear Senator Harkin:

This is in response to the telephone request from Ms. Mary Orr of your staff, to Matthew Straus, asking for the Environmental Protection Agency's (EPA's) definitions of "household waste" and "scrap metal." Both terms have been defined by EPA in regulations issued pursuant to the Resource Conservation Recovery Act (RCRA).

"Household waste" is defined in 40 CFR Section 261.4(b)(l) as:

...any material (including garbage, trash and sanitary wastes in septic tanks) derived from households (including single and multiple residences, hotels and motels, bunkhouses, ranger stations, crew quarters, campgrounds, picnic grounds and day use recreation areas).

This is to make clear that normal household garbage, i.e., waste from residences, is not hazardous waste under RCRA Subtitle C. However, it should be noted that household-types wastes from other sources (i.e., commercial facilities, office buildings) are not covered by the household waste exclusion and thus, would be regulated under the Federal hazardous waste rules if they are identified or listed as hazardous wastes.

"Scrap metal" is defined in 40 CFR Section 261.1(c) (6), as:
...bits and pieces of metal parts (e.g., bars, turnings, rods, sheets, wire) or metal pieces that may be combined together with bolts or soldering (e.g., radiators, scrap automobiles, railroad box cars), which when worn or superfluous can be recycled.

EPA regulations provide that such metal parts, when recycled, are not regulated under the Subtitle C regulations. (See 40 CFR Section 261.6(a)(3)(iv).)

I trust this information is useful to you. If I can be of further assistance, please contact me at (202) 382-4627.

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