Memo Detail

Full Document:PDF Link
RCRA Online Number: 11958
Title: MANAGEMENT AND DISPOSAL OF WASTE VINYL MINI BLINDS
Document Date: 1996-07-12
To: Toro
From: Helms
Organization of Recipient: Consumer Product Safety Commission
Description: Toxicity characteristic (D008) lead-containing mini blinds are not solid waste if they are returned to the manufacturer for resale in a reverse distribution system. Blinds from homes, apartments, and hotels are exempt household hazardous waste (HHW). Waste from hospitals, offices, day care centers, and non-residential buildings at military bases are not HHW. HHW and non-HHW must be segregated. A generator can test waste or apply knowledge. The most conservative approach assumes that the blinds are hazardous waste (HW). The generator is vulnerable for enforcement for an incorrect determination if subsequent EPA testing reveals that the waste is HW.
Regulatory Citation(s): 261.24, 261.4(b)(1), 261.2
RPPC Number: 9451.1996(07)
Official ORCR Policy: Yes
Associated Topic(s): Characteristic Wastes, Exclusions (RCRA), Generators, Hazardous Waste, Household Hazardous Waste