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Yes, the Agency confirmed in the preamble to the Hazardous Waste Generator Improvements Final Rule that wood treaters who are VSQGs may accumulate hazardous wastes on-site using drip pads provided they comply with the 40 CFR Part 265 Subpart W technical requirements. Previously, the Agency had acknowledged in its technical guidance document, Wood Preserving Resource Conservation and Recovery Act Compliance Guide: A Guide to Federal Environmental Regulation, EPA-305-B- 96-001, (June 1996) at section 3-8, that VSQG wood treaters may accumulate hazardous wastes on drip pads. However, they could only do so if they complied with the technical requirements of 40 CFR 265 Subpart W.