ASTM Letter to EPA

On behalf of ASTM Committee C09 on Concrete and Concrete Aggregates and Subcommittee C09.24 on Supplementary Cementitious Materials, we are writing in regards to the proposed classification by the Environmental Protection Agency (EPA) of fly ash as a "hazardous waste".
We strongly encourage the EPA to consider the negative implications of classifying fly ash as a "hazardous waste" under subtitle C of the Resource Conservation and Recovery Act (RCRA). Designation of fly ash as a "hazardous waste" will require that the ASTM standard for use of fly ash in concrete be revised to reflect this classification. A "hazardous waste" designation, even with an exclusion for beneficial use, would cause the ASTM standard for fly ash to be removed from project specifications due to concerns over legal exposure, product liability, and public perception. This will likely result in little or no fly ash being used beneficially in concrete or other applications that support sustainability objectives.
ASTM International is one of the largest voluntary standards development organizations in the world and is a trusted source for technical standards. Originally known as the American Society for Testing and Materials, ASTM was formed over a century ago and has been assisting industry, government and environmentalists by creating consensus standards that have made products and services safer, better and more cost-effective.
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