June 6, 2006

Susan Bodine

Assistant Administrator

Office of Solid Waste and Emergency Response

Mail Code: 5101T

U.S. Environmental Protection Agency 

Ariel Rios Building, 5101T 

1200 Pennsylvania Avenue, N. W. 

Washington, DC 20460

Re:	Meeting on Revision to the Definition of Solid Waste

Dear Assistant Administrator Bodine:

Thank you for meeting with us on revising the definition of solid waste
on May 24th.  We appreciate you taking time out of your busy schedule to
discuss this important topic.   SOCMA is the leading trade association
representing the batch and custom chemical industry with approximately
270+ members. Over 80% of SOCMA members are small businesses with
limited resources.  SOCMA members have shifting product lines that
result in changing waste streams and pay a high disposal cost on
secondary materials that might otherwise be valuable for recycling or
reuse.     

As we discussed at our meeting, we have and will continue to advocate to
EPA to adopt a focused conditional exemption to the requirements of the
RCRA definition of solid waste (“DSW”) regulations that would
recognize the unique scenarios of the toll manufacturing within the
specialty batch chemical sector to reuse and recycle secondary materials
in a manner that would preserve resources and provide significant cost
saving to this competitive sector of the U.S. economy.

SOCMA commends EPA for its collaborative effort with our industry sector
on this important issue.  Also, we thank both you and the OSW staff for
continuing to give our proposed conditional exemption serious
consideration.  Thanks again, and if you should have questions or would
like additional information, please contact me at (202) 721-4198 or at  
HYPERLINK "mailto:gunnulfsenj@socma.com"  gunnulfsenj@socma.com .

Sincerely,

Jeff Gunnulfsen

Manager, Government Relations

SOCMA

