hazardous waste

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By James L. Curtis, Kay R. Bonza, and Craig B. Simonsen

Seyfarth Synopsis:  A railcar cleaning company and its executive officers were recently charged in a 22-count indictment with conspiracy, violating worker safety standards resulting in worker deaths, violating the Resource Conservation and Recovery Act (RCRA), and for submitting false documents to a federal agency.

Nebraska Railcar…
Continue Reading Company and its Executives/Owners Charged With Criminally Violating Worker Safety and Environmental Laws That Led to Workers’ Deaths

By Jeryl L. Olson, Andrew H. Perellis, Kay R. Bonza, Patrick D. Joyce, and Craig B. Simonsen

Book with Environmental Law word on table in a courtroomSeyfarth Synopsis: The EPA’s new “Hazardous Waste Generator Improvements Rule,” while containing some changes that industry welcomes, also contains new requirements that present challenges for the regulated community. We will be publishing a series of blogs on the …
Continue Reading Big Changes Coming – EPA Publishes its Hazardous Waste Generator Improvements Rule

By Jeryl L. Olson, Patrick D. Joyce, and Craig B. Simonsen

bottleSeyfarth Synopsis: EPA publishes new Retail Strategy in an attempt to address the unique challenges the retail sector faces in complying with RCRA’s hazardous waste regulations.

The regulation of hazardous waste in stores, warehouses and during reverse logistics processes in the retail sector has been fraught…
Continue Reading EPA’s New Strategy for Addressing the Retail Sector under RCRA

By Patrick D. Joyce, Jeryl L. Olson, and Craig B. Simonsen

shutterstock_178475264The U.S. Environmental Protection Agency this week released a pre-publication copy of a proposed rule on pharmaceutical hazardous wastes in healthcare and related industries that will significantly affect our healthcare clients. 80 Fed. Reg. 58014 (Sept. 25, 2015).

Under the proposed rule, aimed at hospitals, clinics, nursing…
Continue Reading EPA Says “Stop” – Don’t Dump Those Drugs Down the Drain

By Jeryl L. Olson and Patrick D. Joyce

Our retail clients with stores and warehouse facilities in the State of New York are warned that the State of New York Department of Environmental Conservation (NYDEC) has announced that it will begin enforcing regulations relating to hazardous waste against big boxes, supermarkets, pharmacies and other retailers which generate waste materials…
Continue Reading Warning! Retailers’ Environmental Enforcement Initiative in New York

By Patrick D. Joyce, Philip L. Comella, and Craig B. Simonsen

The U.S. Environmental Protection Agency’s struggle to distinguish between a waste and a recyclable material, dating back to its original May 19, 1980 rulemaking under the Resource Conservation and Recovery Act, takes its latest turn in the now-final Definition of Solid Waste rule (DSW rule), signed by Administrator…
Continue Reading EPA Publishes Massive Final Definition of Solid Waste Rule

By Philip L. Comella and Craig B. Simonsen

The U.S. Environmental Protection Agency recently published its final rule for the national electronic manifest (e-Manifest) system, which upgrades the current paper-based system of tracking hazardous waste shipments and disposal.  79 Fed. Reg. 7518 (February 7, 2014).

The rule indicates that it affects approximately 160,000 entities in at least forty-five industries that…
Continue Reading EPA Final Rule for Modification of the Hazardous Waste Manifest System

By Jeryl L. Olson and Craig B. Simonsen

The U.S. Environmental Protection Agency (EPA) yesterday released a Notice of Data Availability for “Hazardous Waste Management in the Retail Sector.” 79 Fed. Reg. 8926 (February 14, 2014).

An impetus for the Notice was President Obama’s Executive Order 13563, Improving Regulation and Regulatory Review, “which charges federal agencies to monitor regulatory…
Continue Reading EPA Rulemaking on Hazardous Waste Management in the Retail Sector

Philip L. Comella, and Catherine McCord, of Heritage-Crystal Clean LLC, will co-present a Bloomberg BNA environmental webinar, on “The EPA’s New E-Manifest: Understanding the Changes to RCRA’s Cradle-to-Grave System”.

We had previously blogged about the U.S. Environmental Protection Agency’s public hearings on this topic, and about its subsequent request for information about e-manifest systems. For the past 33…
Continue Reading EPA’s New E-Manifest: Understanding the Changes to RCRA’s Cradle-to-Grave System

By Philip L. Comella and Craig B. Simonsen

We had previously blogged about the U.S. Environmental Protection Agency’s announced public meetings to “obtain public input from stakeholders” on a national electronic manifest (e-manifest) database system intended to capture information on shipments of hazardous wastes.

The Agency has now published a Request for Information (RFI) on the concept of…
Continue Reading EPA Request for Information on Electronic Manifest (E-Manifest) Systems