ASBG supports most of the initiatives that are outlined in the strategy with the exception of the presence based approach to asbestos and recommending guidance documents on how the EPA will enforce its asbestos waste laws clarifying what is the wrong thing and what are the right things as identified. ASBG reserves most of its comment on the potential material impacts that a heavy handed strategy can cause the C&D recycling sector. A list of considerations are provided that would be beneficial inclusions to the strategy. Also raised is the lack of consideration to the supply and lowering of costs for commercial quantities of asbestos wastes.
 ASBG's Submission on the EPA's Asbestos Strategy - 2018 | 842 kB |
