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DEP > Innovation > Toxic and Hazardous Waste Reduction > Advisory Opinions

Toxics Program - Advisory Opinion #6:
Revised 4/24/03

Toxics Use and Hazardous Waste Reduction Law (Toxics Law), as amended by PL 1999, Chapter 348, "An Act to Encourage Continuous Improvement in Pollution Prevention in Maine".

Section 2304-A Regulated Community, Section 2305 Pollution Prevention Plans,
and Section 2305-A Progress Reports.

Question: If a company uses or releases a variety of toxics, some above the reporting thresholds specified in Section 2304-A, and some below the reporting thresholds, must the company include the toxics that are below the reporting thresholds in their Pollution Prevention (P2) plan and on their biennial reports submitted to the Department?

Response: Section 2304-A stipulates that plans and reports must be submitted by the
following facilities:

  1. Facilities subject to reporting requirements for extremely hazardous substances under the SARA, Title III, Section 312.
  2. Facilities required to report under the SARA, Title III, Section 313; and
  3. Facilities that ship more than 2,640 pounds of hazardous waste in a calendar year.

Therefore, Section 2303 establishes non binding state wide goals for toxics use, toxics release, and hazardous waste reduction using the same baseline dates for toxics and hazardous waste generation established in the "original TUR Law". The reduction goals established in Section 2303 (40% by 2002, 50% by 2004, and 60% by 2006), build upon the 30% reduction goal established in the "original TUR Law".

Based on the above, it is the Department's interpretation that the intent of the "amended Toxics Law", is to maintain consistency in the type of data reported under the Law. Therefore, planning and reporting is only required for those toxics used and toxics released above the thresholds noted above.

Given that the above hazardous waste threshold is based on a facility wide total of all hazardous waste shipped, once the threshold is exceeded, a facility must include all of the hazardous waste shipped in its reduction plan and biennial reports, unless the waste or facility is specifically exempt under Section 2304-A (2).