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Ms . Angie Manetti <br /> August 2 , 2018 <br /> Page 3 <br /> 'Any container, or inner liner removed from a container, which previously held a <br /> hazardous material, including but not limited to hazardous waste, and which is <br /> not empty as defined in subsections (b) or (d) of this section, or otherwise <br /> exempt from regulation as a hazardous waste under this division or Chapter 6 . 5 <br /> of Division 20 of the Health and Safety Code (commencing with Section 25100), <br /> shall be managed as a hazardous waste (emphasis added) in accordance with <br /> this division and Chapter 6. 5 of Division 20 of the Health and Safety Code <br /> (commencing with Section 25900) . " <br /> This section clearly requires that non -empty containers be managed as hazardous <br /> wastes . <br /> CONCLUSION <br /> California ' s hazardous waste regulations applicable to containers are more stringent <br /> than their federal counterpart . California adheres to the U . S . EPA' s 1987 interpretation <br /> letter because it is consistent with California regulatory requirements . U . S . EPA' s more <br /> recent 2011 memorandum is inconsistent with California ' s regulatory requirements <br /> applicable to containers ( i . e . , it is less stringent than corresponding state requirements ) , <br /> therefore U . S . EPA' s 2011 memorandum cannot be applied in California . <br /> California healthcare facilities ( hazardous waste generators ) must include the weight of <br /> the container and residue when completing a Uniform Hazardous Waste Manifest . The <br /> combined weight counts toward generator status . DTSC will review this issue again <br /> when U . S . EPA' s new rules for pharmaceutical wastes are promulgated . <br /> If you have any questions or would like to discuss this further, please contact <br /> Renee Roberts of my staff at ( 916 ) 324-8192 or Renee . Roberts@dtsc . ca . gov <br /> Sincerely , <br /> 0 �/(s 4" 0 <br /> Ellen L . Haertle , Chief <br /> Industry Assistance , Training and Outreach Unit <br /> Policy and Program Support Branch <br /> Hazardous Waste Management Program <br /> Enclosure <br /> cc : See next page . <br />