From: "Margaret Rakas"Date: March 19, 2009 2:04:15 PM EDT Subject: Re: [DCHAS-L] Procuring Acetonitrile Also it's a good idea to check with your state authority charged w/ implementing RCRA. As of a few years ago (last time I checked) my understanding was that our state had more stringent rules about distilling waste solvent for recycling purposes than RCRA, in terms of recordkeeping and other requirements. At that time, it was definitely not a matter of "oh, just go ahead and do it...", at least according to a presentation I attended which featured EH&S folks from one of the bigger universities in Boston (I don't remember which one). So your state's requirements or "take on this" might be the same as those of Federal RCRA, or more stringent, but would also be a factor in this activity... The above is my personal opinion only, not legal or business advice and may not be the opinion of my employer or any group to which I belong.. Margaret Rakas
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