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EPA is determined to get reports from solvent recyclers under the TSCA Chemical Data Reporting rule (formerly IUR).  From their “Q&A Document on Recycling and the TSCA Chemical Substance Inventory“:

Question C. 8 We have facilities that recycle spent solvents. The spent solvents are received as a hazardous waste and are often complex mixtures of different types of solvents. These materials are re-distilled to remove water and other contaminants and to separate the various solvents, and are re-sold as solvents. Is the recycling of the solvents a “manufacturing” activity?

A: In this case, the spent solvents are considered to be byproducts of use. However, according to 40 CFR 720.30(g), the manufacture of a byproduct is exempt from reporting when the byproduct is solely used to extract a component chemical substance from the byproduct. The extracted component chemical substances, the various purified solvents this case, are reportable chemical substances.

Contact EHS Strategies, Inc. for help.

 

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