HAZARDOUS WASTE TRACKING AND CO-GENERATION.

The article focuses on the issue of co-generation in tracking hazardous waste in the U.S. It is a lesser known fact that if a contractor operates a manufacturing process for a company and that process generates hazardous wastes, the generator and contractor will be considered by the U.S. Environmental Protection Agency (EPA) to be co-generators of those wastes. As the owner of the manufacturing process, the generator also owns the wastes from the process. In other words, generators could also be liable for the wastes they have produced and be fined if they fail in the Resource Conservation and Recovery Act (RCRA). The author concludes that the best way to protect the generator is to have an agreement that clearly states the contractor's responsibilities for managing waste.