Many chemical manufacturers and chemical marketers are using contract manufacturers; ie, tollers, to reduce product development cycle time. Such companies expend considerable effort to ensure safe operation of the process at a toll facility and to ensure production of quality product by the toll facility. Waste management and waste disposal are sometimes lost in the rush to produce a new product. However, waste disposal should be the second highest item on the "to do" list for a potential tolling project. Why? Because people go to jail for mishandling waste. And, ignorance of waste disposal law is not a viable legal defense. This paper outlines the issues involved with managing waste generated by a new chemical product at a toll facility.

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