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• Discuss Walmart ‘s comments in response to Executive Order 13563 -
Improving Regulation and Regulatory Review
• Request EPA’s consideration for further discussions on the issues
presented in Walmart ‘s comments to find solutions that remain
protective of human health and the environment.
Walmart Confidential Business Information
Objectives
“Well, if it goes in your coffee, it is not hazardous waste.”
President Obama, Wall Street Journal, Jan. 18, 2011 at A17.
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• Complex Regulatory Requirements
• Breadth of Compliance
• Number of Facilities
• 100% Compliance 100% of the Time
• Skills Gap
Challenges to RCRA Execution in the Retail World
Walmart Confidential Business Information
4
RCRA Regulation of Consumer Goods
Walmart Confidential Business Information
* Approximates
0.5% of 1.7 billion
regulated items
sold are managed
as Hazwaste by
Walmart
(10 Million)
100 Billion Items
Sold to Consumers
0.01% managed as
Hazwaste by Walmart
(10 Million)
1.7% of 100 Billion
Items Sold are RCRA
regulated if waste
(1.7 Billion)
Solid Waste
Hazardous
Waste
5 Walmart Confidential Business Information
The Confusing World of Consumer Products as Hazardous Waste
A typical Walmart Supercenter contains over 500,000 individual items (SKUs)
Product make-up is trade secret
MSDS not required to indicate if product
RCRA regulated if it becomes a waste
These products are regulated under other
regimes and are “safe” for consumer use
AND consumer disposal
If it is safe to consume or place on your
body or play with and 99.5% of it is
disposed of in municipal landfills – does it
make sense to manage 0.5% of the exact
same product as HW?
6 Walmart Confidential Business Information
Lead Acid Batteries
Universal Waste
Mercury Lamps & Equipment
Recalled Pesticides
Hazardous Waste Acute Hazardous Waste
Vitamins
TCLP –Selenium/Chromium
Aerosols
D001
D003 - Reactive?
Are they empty?
P-Listed
Not Hazardous
7 Walmart Confidential Business Information
Not Solid Wastes
Cathode Ray Tubes
40 CFR 261.4(a)(22)
Shredded Circuit Boards
40 CFR 261.4(a)(14)
Are these Hazardous Waste?
Electronic Kung-Fu Panda Doll Food Processor
Kid’s Make-up Set Kid’s Clothing Set
w/ Lead in Zipper
8 Walmart Confidential Business Information
EPA proposed Universal Waste Rule – 73 Fed. Reg. 73520 (Dec. 2, 2008)
“Facilitate better management of pharmaceutical
wastes…”
“Ensures that these hazardous pharmaceutical
wastes are properly disposed of and treated as
hazardous wastes.”
“…opportunity for all pharmaceutical
wastes, hazardous or not, to be managed as a
single waste stream.”
“…reverse distribution system for
pharmaceuticals helps ensure that unused and
expired pharmaceuticals do not get diverted to
inappropriate uses, and that the returned
pharmaceuticals, are managed appropriately.”
Pharmaceutical Consumer Products
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Regulatory Focus on Retail
Increasing Regulatory Interest
• Total Environmental Regulatory
Contacts
1,035 - FY’09 and 2,466 - FY’11
• “Waste” Related Contacts
543 - FY’09 and 1,533 - FY’11
• 138% and 182% increases
respectively
Walmart Confidential Business Information
62%
38%
Regulatory Activity - FY'11
Waste Related
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• Finalize Pharmacy Universal Waste Rule
• Reconsider UW Rule for Consumer Products
72 Fed. Reg. 23281 (Apr. 30, 2007)
“This proposed action will streamline the current
regulations governing these wastes, ensuring
that… consumer product wastes are properly
managed...”
• Establish workgroup to clarify complex
retail regulatory issues, such as:
– Aerosols
– Electronic devices
– Reverse Distribution
– Bagged FIFRA pesticides
Walmart Confidential Business Information
Conclusion