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| Full Document: |  |
| Title: | CLARIFICATION ON WHEN USED MERCURY RELAYS/SWITCHES BECOME SPENT |
| RCRA Online Number: | 11876 |
| Date: | 09/28/1994 |
| To: | Green |
| From: | Bussard |
| Organization of Recipient: | Applied Environmental Sciences, Inc. |
| Description: | Mercury switches taken out of service and reclaimed are spent materials and solid wastes (SW). Sending a mercury switch for further use as a relay or switch is the continued use of a product. The actual management of a material rather than the potential of a material for a particular end use determines if it is a SW. Whether a switch is spent or directly reusable is determined when it is removed from service. Out-of-date drugs are off-specification CCPs and not a SW when returned to the pharmaceutical manufacturer for reclamation. Persons may petition to include switches/relays as a universal waste (SEE ALSO: 70 FR 45508; 8/5/05). |
| Regulatory Citation(s) : | 261.1(c)(1), 261.2(c)(3), 273.1  |
| Statutory Citation(s): | NA Read US Code 42, Chapter 82 |
| Topic(s): | Hazardous Waste; Hazardous Waste Recycling; Mercury Wastes; Petitions; Universal Waste |