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States' Adoption of Rules Involving HSWA Effective Dates: Flynn/Pressman Memo

State laws can not extend Hazardous and Solid Waste Amendments (HSWA) compliance dates. Since a state's listing or characteristic rule is generally promulgated after the federal rule, the state's rule will usually have a later effective date. Thus the state's Part A submission/compliance deadline could be later than the federal deadline, unless the state specifically adopted the federal effective date or federal compliance deadline. 

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