“Many NACD members and their customers generate used drums and transport them to reconditioners,” said Gibson. “They do so carefully, ensuring that they meet each of their regulatory obligations as they follow operating procedures required by Responsible Distribution®, and many also supplement these procedures with their own best practices.”

Gibson underlined NACD’s concerns that new, burdensome regulations will add significant strain on reconditioners and other stakeholders, while forcing more containers to be prematurely recycled or sent to landfills. 

“NACD respectfully requests that the EPA reconsider many of the regulatory changes considered in this ANPRM,” continued Gibson. “The current Resource Conservation and Recovery Act (RCRA) regulations have been highly effective in ensuring the safe and proper preparation, transport and reconditioning, recycling, or disposal of used containers that held hazardous products. NACD fears that adopting new regulations that significantly alter the drum reconditioning industry would result in reconditioners closing their doors or significantly increasing their prices, causing fewer drums to be reconditioned and creating more waste and emissions. Instead, NACD urges the EPA to focus on improving its guidance and outreach to reconditioners, used drum generators and transporters to better ensure that current regulations are followed.”

Gibson concluded, “By working together with the regulated entities to ensure they understand their obligations and by incorporating non-regulatory strategies such as performance-based standard operating procedures, the EPA can improve compliance with current regulations. This should be the EPA’s goal as the agency’s concerns outlined in this ANPRM occur when current regulations are not followed.”

For more information, visit: www.nacd.com.