Dear CDIM Partners:
I am writing now to make you aware of a process being undertaken by CalEPA Department of Toxic Substances Control to reevaluate California’s hazardous waste standards. California generates over 1.5 million tons of manifested hazardous waste each year. Nearly half of California’s hazardous waste is shipped to other states where it is no longer considered hazardous. It is an unconscionable failure of public policy that California sets the most stringent standards in the nation for defining what constitutes hazardous waste and then simply trucks hazardous waste to Arizona, Nevada and Utah for disposal in non-hazardous waste landfills, while generating a vast amounts of transportation air emissions in the process.
DTSC has published the 2025 Draft Hazardous Waste Management Plan, A Modern Approach to a Circular Economy (the Plan) and is now undertaking a public outreach effort to gain feedback so that it can adopt the plan and move forward to efforts to update its regulations and policies.
VIEW THE PLAN HERE
COMMENT ON THE PLAN HERE
DTSC, via its Board of Environmental Safety, is hosting a series of hearings, the next of which is May 15, 2025 from 4:45 to 8PM.
MEETING LOGIN INFO HERE
CDIM particularly supports the technical aspects of “Goal 6: Remain at forefront of environmental and public health protection by ensuring proper identification of hazardous waste” and “Goal 7. Identify alternative management standards for certain non-RCRA hazardous wastes while ensuring protection of public health and the environment.” Tactics to achieve these goals are described in Appendices J (Waste Extraction Test), Appendix K (Non-RCRA Metals), Appendix L (STLC and TTLC), and Appendix M (AMS for Non-RCRA Soil).
CDIM has prepared a template comment letter that can be used for expressing support for DTSC's effort and stating that California must re-evaluate out-of-date test standards and criteria and must consider modern landfill design standards in deciding whether to allow certain low risk waste to be managed safely and locally.
If California wants to lead the nation in environmental protection, it must do the technical work to remedy the unintended consequences of its outdated hazardous waste regulations. We encourage our partners in the environmental industry to provide their input to this process, and it has potential to lead to significant positive changes to our work.
Respectfully,
Scott Bourne & the CDIM Team