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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 25100)." <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 /> 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 />