Product
Overview
PreTox
2000 Fast Dry
PreTox
7000 Stripper
PreTox
2000 DM
Product
Acceptance
Product
Development
Related
www sites
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Product Acceptance and
Compliance
In the early stages of PreTox development, NexTec, Inc. was
known as Progressive Technologies, Inc. To ensure that there were no regulatory barriers
to the use of the PreTox System, NexTec, Inc. sought the approval of the EPA. While the EPA
will not endorse specific products, it will render an interpretation of applicable
regulations. As you can see in the letter from the EPA,
if a waste passes the TCLP test, it is non-hazardous for disposal, regardless of removal
process. The PreTox System is part of the removal process. The EPA goes on to say,
"that wastes must continue to pass the TCLP test". The PreTox System is the
superior choice for lead paint removal because it prevents lead leachibility indefinitely.
The EPA, in the letter goes on to say, "CERCLA
liability is independent of any hazardous waste determination that may be made". This
means that CERCLA (Superfund) liability is inescapable, no matter where your waste is
landfilled.
Finally the EPA states, "for the purposes of hazardous
waste generation, the term "generator" may refer to both the paint abatement
contractor and to the owner of a building or a superstructure and they are considered
"co-generators" of the waste. A generator of a waste has joint and several
unlimited liabilities under CERCLA (Superfund). Does that get your attention?
Certainly, it makes more sense to generate a non-hazardous
waste in all situations. It's the right thing to do for the environment and for your
company.
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4050 Westmark Drive. Dubuque, Iowa 52002 www.pretox.com
1-800-338-8296