California’s Department of Toxic Substances Control (DTSC) established waste management rules for solar photovoltaic (PV) modules, to become effective on January 1, 2021. These rules are adopted under the state Hazardous Waste Control Law (HWCL), applying “universal waste” authority permissible under the federal Resource Conservation and Recovery Act (RCRA) and Environmental Protection Agency (EPA) RCRA regulations. EPA defines five universal waste categories, and also allows states to define additional categories (I wrote about this HERE). The remainder of today’s blog summarizes these universal waste PV requirements (which include dozens of revisions to proposed state rules I discussed HERE).
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