Companies Should Engage With EPA on PVC Hazard Designation

Walk around your basement – see those pipes?  Would you consider those pipes to be hazardous waste? What about rain boots?  Garden hose? Shower curtain?  Traffic cones? All of these and more have the potential to be designated and handled as hazardous waste under a current petition to the United States Environmental Protection Agency (EPA) under the Resource Conservation and Recovery Act (RCRA) to designate discarded products containing polyvinyl chloride (PVC) as “hazardous waste.”  Per a proposed Consent Decree, EPA will decide by January 2023. This is definitely an issue to watch.