Proposed Revision of the Definition of Solid Waste
The Environmental Protection Agency (EPA) of the United States is proposing revisions that could have the perverse effect of limiting the conservation and recovery of metals such as nickel from solid waste.
The EPA is taking an unnecessarily narrow and restrictive approach to the definition even though repeated
court rulings have encouraged the EPA to do otherwise. At risk of being lost to society are the metals
contained in products/materials such as spent catalysts, pollution control dusts and wastewater treatment
sludge from metal finishing operations.
The comments filed by the Nickel Institute today
examine how the nickel industry and its customers responsibly recover and recycle nickel now and could do
more in the future. The comments offer solutions to the current situation and emphasize that the nickel
industry is not seeking an unconditional exclusion from the definition of solid wastes: all could be
accomplished within an appropriate and protective regulatory regime.

