This comment addresses the ramifications of the invalidation of RCRA's mixture and derived-from rules by Shell Oil Co. v. USEPA. The author argues that EPA should repromulgate the rules while moving to adopt a more risk-based management strategy under which wastes will be exempt from Subtitle C regulation pursuant to their location along a proposed "continuum of control."
Recommended CitationLori Caramanian, Hazardous Waste Management After Shell Oil , 11 Pace Envtl. L. Rev. 265 (1993)
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