By James L. CurtisKay 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

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

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,

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

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

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

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

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