Published in December 2019 Focus on the Environment Newsletter
In 2018, the Ohio EPA proposed to merge the industrial solid waste landfill rules (Ohio Administrative Code Rule 3745-29) with the residual solid waste landfill rules (OAC Rule 3745-30) and concurrently rescind Rule 3745-29. This is a logical step, as the requirements of the two sets of rules are very similar except for the definition/classification of a residual waste landfill. On December 6, 2019, the Ohio EPA released an Interested Party draft of the changes to the industrial solid waste (ISW) and residual solid waste (RSW) rules. The rules package proposes to rescind Rule 3745-29 altogether and incorporate those requirements into Rule 3745-30.
As explained in the Interested Party Factsheet, the proposed Rule 3745-30 includes revisions that merge the ISW/RSW programs, wordsmithing to bring the text in compliance with Ohio EPA rule-writing standards, and in many places, replacing the term “director” with “Ohio EPA”, thereby allowing the director to delegate the work to staff, rather than making those actions mandatory for the director. In addition, Rules 3745-27-15 and -16 (financial assurance for solid waste facilities and sanitary landfill facilities, respectively) are being revised to remove references to Rule 3745-29.
Significant specific changes include the following:
Specific changes for each rule (i.e., redline strikeout and added text) can be seen at the Ohio EPA Division of Materials and Waste Management’s non-hazardous waste rules webpage under “ISW/RSW Interested Party Release” in the “Interested Party” tab.
The Ohio EPA is accepting comments on the proposed rules until 5:00 pm on January 21, 2020. Send comments to Michelle Mountjoy at firstname.lastname@example.org or by postal mail at
Michelle Mountjoy, Rules Coordinator
Division of Materials and Waste Management
P.O. Box 1049
Columbus, OH 43216-1049
Steve Williamson is a Senior Scientist with Cox-Colvin & Associates, Inc. He holds a BS degree in Environmental Health and an MS degree in Hydrogeology from Wright State University. Mr. Williamson has over 30 years' experience working on brownfields, solid and hazardous waste, and groundwater contamination projects in Ohio and the Midwest.