The Retail Industry Leaders Association (“RILA”), the Food Marketing Institute (“FMI”), the National Association of Chain Drug Stores (“NACDS”), the National Retail Federation (“NRF”), the National Grocers Association (“NGA”), and their members (collectively, the “Retail Associations”) are pleased to submit these comments in response to the proposal of the U.S. Environmental Protection Agency (“EPA” or the “Agency”) to overhaul and “improve” the requirements for hazardous waste generators under the Resource Conservation and Recovery Act (“RCRA”). See 80 Fed. Reg. 57,918 (September 25, 2015). 

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