By Jeryl L. Olson, Patrick D. Joyce, and Craig B. Simonsen
Seyfarth 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 Jeryl L. Olson, Ilana R. Morady, Patrick D. Joyce, Philip L. Comella, and Craig B. Simonsen
The Pipeline and Hazardous Materials Safety Administration (PHMSA) just announced that it has amended the Hazardous Materials Regulations (HMR). 81 Fed. Reg. 18527 (March 31, 2016).
It has done so by adopting its proposed regulatory amendments applicable to the reverse
Continue Reading DOT Publishes Final Rule on “Safe Reverse Logistics” for Retail “Returns” of Hazardous Materials to Distribution Centers
By Jeryl L. Olson and Craig B. Simonsen
The Pipeline and Hazardous Material Safety Administration (PHMSA) has proposed to modify its hazardous materials regulations as it affects the retail industry by adding a definition for “reverse logistics.” 79 Fed. Reg. 46748 (August 11, 2014).
PHMSA has been working on the proposal since July 2012, when it had requested public comment
Continue Reading Retail Industry Update: DOT’s “Reverse Logistics” Rulemaking to Add Exception for Transportation of Hazardous Materials