In response to an ACMA petition, in 1997, the EPA approved polymerization for the treatment of scrap resin, at the site of generation, without having to obtain a waste treatment permit. The polymerization must occur in tanks, containers or containment buildings, and these units must comply with the standards for so-called 90-day generator tanks, containers and containment buildings. A written waste analysis plan is required, and the amount of scrap resin that is polymerized counts toward the amount of waste generated monthly. Generators should ensure that the resulting polymerized resin does not itself exhibit the characteristic of ignitability; many composite manufacturers who use polymerization to treat resin break open the drums to ensure that no ignitable liquids remain.
Generators of hazardous waste must generally comply with the same Occupational Safety and Health Administration regulations that apply to manufacturers who handle the same materials. For example, scrap resin management activities must comply with the same permissible exposure limits and hazard communication requirements as resin processing operations.