Full Document:
RCRA Online Number: 14851
Title: APPLICABILITY OF RCRA REGULATIONS TO NICOTINE RECLAMATION PROCESS
Document Date: 2015-05-08
To: DeMuth
From: Johnson
Organization of Recipient: g2revolution, LLC
Description: Nicotine-containing gums, lozenges, patches, and e-cigarettes are considered acute hazardous waste under the RCRA regulations at 40 CFR 261.33(e) for nicotine and salts (EPA waste code P075) and thus may be subject to hazardous waste regulation when discarded. EPA has concluded that, provided the nicotine-containing products are being legitimately recycled according to 260.43, the nicotine-containing products would not be considered solid waste and thus are not subject to RCRA hazardous waste regulation when sent for nicotine reclamation. This memorandum also discusses the regulatory status of waste streams generated from the reclamation process, including batteries from e-cigarettes, recycling process water, gum residue, and patch fabric.
Regulatory Citation(s): 260.43, 261.2, 261.4(a)(1)(ii)
Statutory Citation(s): 3006 Read US Code 42, Chapter 82
Official ORCR Policy: Yes
Associated Topic(s):
Hazardous Waste Recycling,
Identification of Hazardous Waste,
Listing Hazardous Waste,
P-wastes |