Today, the Institute of Hazardous Materials Management [IHMM] filed comments in EPA’s NPRM Docket ID No. EPA–HQ–OAR–2004–0022, Comments on Proposed NESHAP for Hazardous Waste Combustors—Residual Risk and Technology Review; Withdrawal of Proposed Revisions to Standards for Periods of Malfunction (90 Fed. Reg. 50814, Nov. 10, 2025.
IHMM addressed the statutory and best practices elements of this proposed rule from the perspective of IHMM’s CHMMs and CHMPs, and the comments include a comprehensive compliance-risk matrix of how the proposed rule affects the work of CHMMs and CHMPs.
IHMM also made recommendations to the EPA concerning state-level implementation guidance implementing the proposed revisions to the Hazardous Waste Combustor (HWC) NESHAP resulting from EPA’s Residual Risk and Technology Review (RTR).
As IHMM does with all comments on any agency’s proposed rules, we also highlighted the background and experience of CHMMs and CHMPs by including the credential blueprints of each and outlining the recertification, continuing education, and accreditation standards of IHMM’s credentials. As we want all government agencies to know about our credentials, this background information is an integral part of all of IHMM’s comments in the hazmat, dangerous goods, and safety EHS areas of interest.
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