By Jeryl L. Olson and Craig B. Simonsen

Seyfarth Synopsis:  Last week the U.S. Environmental Protection Agency (EPA) finalized a “streamlined system” for managing hazardous waste aerosol cans as Universal Waste.  The Agency believes that the new system will be “clear, practical, and protective” and will promote recycling, and estimates the change will save

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 Brent I. Clark, James L. Curtis, and Craig B. Simonsen

Safety at workThe U.S. Department of Justice (DOJ) and the Department of Labor (DOL) announced last week an expansion of its worker endangerment initiative to address worker safety violations through the use of enhanced criminal fines and penalties.

According to Deputy Attorney General Sally

By Philip L. Comella and Craig B. Simonsen

iStock_000049177646MediumThe U.S. Environmental Protection Agency has promulgated significant new provisions both to its 1988 underground storage tank (UST) regulations and to its 1988 state program approval (SPA) regulations. 80 Fed. Reg. 41566 (July 15, 2015). This is the first major revision to the federal UST regulations since

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

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

By Andrew H. Perellis

It’s an all too familiar scenario. You learn that your drinking water supply has been contaminated by a defunct manufacturing operation on adjacent property.

In response, you file a lawsuit involving RCRA’s citizen suit provisions to allege that the former owner or operator violated RCRA’s substantive requirements by disposing of hazardous

By Meagan Newman and Craig B. Simonsen

The U.S. Environmental Protection Agency has 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.

Specifically, the purpose of the meetings is to solicit comments from the states, industry,

By Andrew H. Perellis and Philip L. Comella

In an important decision concerning the application of the Resource Conservation and Recovery Act of 1976 (RCRA) criminal penalties, the U.S. Supreme Court recently held, in Southern Union Co. v. US, __ U.S. ___, 132 S.Ct. 2344, 2012 WL 2344465 (June 21, 2012), that the duration