The team at DLH has discussed the issue of the recycling rebate. Several questions were raised:

1)In that the proposed legislation is so loosely written, how long before the program will be ramps-up?

2) Who will write the administrative structure?

3) At what level will the program be administered? Regionally? Locally?

4) Which federal/state agency will perform weighing and accounting responsibilities? Will the named agency have a synergistic relationship with the IRS (perhaps even for reasons of intervention in the event of a shopowner's audit? For obvious reasons, it shouldn't be left to commercial waste management companies to do so - that could give the appearance that this legislation is the product of a lobbying effort.

5) Who will calibrate the scales used for weighing?

6) Many waste stream products can be proven non-hazardous by TCLP testing. Could it be argued that Bill H.R. 316 could set a generator up for tax fraud? Many generators have commercial waste haulers remove their waste products simply because they aren't aware of other alternatives.

7) As environmental actions are typically trumpeted from the rooftops, how is it that this particular legislative proposal has not been waved like a banner by it's author?

We ask these questions only to protect the compliance interests of the painting/coating industry. We must play Devil's Advocate in order to look ahead and see what pitfalls could be created. If our questions can be answered in a fashion that insures the industries we serve will benefit and be insulated from additional regulatory headaches or tax issues, we feel that the spirit of this piece of legislation would be successful.

-- Tara Munro (DLHE1@aol.com), May 08, 1997

Answers

Please note that our URL has changed.. we can be found at www.dlhe.com. Please make a note of the new address - we'd hate to think we left anybody behind. The address may be different but our site is the same..full of information that can be very helpful for painting/coating professionals !!

-- Tara L. Munro (dlhe1@aol.com), June 27, 1997.