Resource Conservation and Recovery Act

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

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 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 of misconduct underlying the imposition
Continue Reading Supreme Court Holds that Jury, not Court, Must Decide Duration of Misconduct Underlying Criminal Fines under RCRA