How should precious metals destined for reclamation be handled?
Precious metals in non-RCRA hazardous matrices (not hazardous wastes), like gold, platinum, or palladium are not regulated under EPA as a hazardous waste. The EPA does regulate precious metals like silver, or any precious metal containing hazardous constituents, like cyanides. Precious metals wastes destined for reclamation need only be labeled something to the effect of “silver salts for reclamation” or “scrap gold”. However the EPA prohibits generator speculative accumulation of such materials and requires that 75% of the material be recycled per calendar year. Records showing the volume of the materials stored at the beginning of the calendar year, the amount received during the year, and the amount remaining at the end of the calendar year must be maintained. Thus recyclers need to keep an accurate log and be able to demonstrate they are processing at least 75% of their accumulated stocks in a calendar year. If the material would be considered a hazardous waste and is being sent of
