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Sierra Chemical Co. Hazardous Waste Management Plan product is retrieved from a client, Sierra Chemical Co. recycles the product as an ingredient into one of its manufacturing processes or as an effective substitute for a commercial product, without treatment or reclamation. These materials that are returned from vendors and reused in the chemical manufacturing process to create raw products are considered an "Excludable, Recyclable Materials" (ERMs) and are excluded from the definition as a hazardous waste as specified in Health and Safety Code (HSC) sections 25143.2(b) and 25143.9. All hazardous materials are handled by Sierra Chemical Co. in accordance with all applicable laws and regulations. Sierra Chemical Co. is currently authorized and licensed to offer for transport specific hazardous materials including sodium hypochlorite, in accordance with 49 CFR sections 100-199. Therefore, when Sierra Chemical Co. retrieves a damaged or unused product(s) from a customer, the material is considered a hazardous material, as opposed to a hazardous waste, according to the U.S. EPA, Cal/EPA and U.S. DOT definitions of a waste. The regulations regarding ERMs are outlined in the next paragraph. Per Health and Safety Code (HSC) Sections 25143.2(b) and 25143.9, recyclable materials recycled in the following methods shall be excluded from the classification as a waste if the material is: Used or reused as an effective substitute for commercial 1) Used or reused as an ingredient in an industrial process to make a product if the material is not Replaces: being reclaimed. ACT Environmental Services, Inc. March 4, 2016 2) Used or reused as an effective substitute for commercial products if the material is not being reclaimed. 3) Returned to the original process from which the material was generated, without first being reclaimed, if the material is returned as a substitute for a raw material for raw material feedstock, and the process uses raw materials as principal feedstocks. These materials must be managed in accordance with HSC 25149.9: a) The material is held within a container or tank and the container or tank is appropriately labeled, marked, and placarded in accordance with the department's hazardous waste labeling, marking and placarding requirements which are applicable to generators, except that the container or tank shall be labeled or marked clearly with the words "Excludable Recyclable Material" instead of the words "Hazardous Waste," and manifest document numbers are not applicable. b) The owner or operator of the business location where the material is located has a business plan that meets the requirements of HSC 25504, including but not limited to, emergency response plans, and procedures, as described in subdivision (b) of Section 25504, which specifically address the material or that meet the department's emergency response and contingency requirements which are applicable to generators of hazardous waste. c) The material shall be stored and handled in accordance with all local ordinances and codes, including, but not limited to, fire codes, governing the storage and handling of the hazardous material. 11, Contin genc y Plan A contingency plan has been prepared for Sierra Chemical Co. in accordance with RCRA requirements codified in 22 CCR section 66260.10 and 40 CFR section 270.14(b)(7). The document defines responsibilities, coordination agreements, health and environmental hazard minimization procedures for fires, explosions, and sudden or non -sudden releases of hazardous materials and waste, and Prepared By: Issue date: Replaces: Page: ACT Environmental Services, Inc. March 4, 2016 NA 18 of 23