Just past the halfway point of 2024, it's already been a busy year for those following regulatory developments related to per- and polyfluoroalkyl substances (PFAS). Building on its plans in the 2021 PFAS Strategic Road Map...more
The United States Environmental Protection Agency (“EPA”) issued a direct final rule on August 9th denominated: Hazardous Waste Generator Improvements Rule, the Hazardous Waste Pharmaceuticals Rule, and the Definition of...more
On April 17, 2015, EPA issued the final coal combustion residuals (CCR) Rule (the 2015 CCR Rule), providing the first federal regulatory scheme for the disposal of CCR materials. The 2015 CCR Rule regulates only facilities in...more
The United States Environmental Agency (“EPA”) released December 19, 2019 interpretive guidance titled: Manifesting Non-Creditable Hazardous Waste Pharmaceuticals – New Four Character Code (“Guidance”) - The document...more
The United States Environmental Protection Agency (“EPA”) issued a pre-publication final rule adding hazardous waste aerosol cans to the universal waste program under the federal Resource Conservation and Recovery Act...more
On November 15, 2019, the Administrator of the U.S. Environmental Protection Agency (EPA) signed a final rule to classify and regulate hazardous aerosol can wastes as “universal wastes” under the federal Resource Conservation...more
Earlier this year, the Environment Protection Agency (“EPA”) adopted a final rule imposing new standards for the management of hazardous waste pharmaceuticals (“HWPs”) that goes into effect on August 21, 2019 (“Final Rule”)....more
Certain pharmaceuticals are regulated under the Resource Conservation and Recovery Act (RCRA) as “hazardous waste” when they are discarded. EPA recently finalized new management standards for hazardous waste pharmaceuticals...more
On February 22, 2019, EPA published its final rule governing standards for the management of pharmaceutical hazardous wastes in the Federal Register (Final Rule). The Final Rule’s publication in the Federal Register sets...more
On December 11, 2018, U.S. EPA Acting Administrator Andrew Wheeler signed a new hazardous waste pharmaceutical rule. The final rule retains a proposed requirement, opposed by industry, that prescription pharmaceuticals sent...more
While much of the environmental bar was focused on the Waters of the U.S. rulemaking, on December 11, U.S. EPA Acting Administrator Andrew Wheeler signed the new hazardous waste pharmaceutical rule. The final rule retains a...more
The Environmental Protection Agency (EPA) has made several recent changes that will affect compliance obligations under the Resource Conservation and Recovery Act (RCRA). First, EPA finalized revisions to the definition of...more
On July 7, 2017, the U.S. Court of Appeals for the District of Columbia Circuit (“D.C. Circuit” or the “Court”) issued a decision invalidating two key elements of the regulatory definition of solid waste under the Resource...more
Seyfarth 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...more
In late October 2016, the United States Environmental Protection Agency (EPA) adopted two final rules that will very shortly change procedures for those who export or import Resource Conservation and Recovery Act (RCRA)...more
The U.S. Environmental Protection Agency published proposed revisions to Hazardous Waste Generator regulations in September 2015. The public comment for the proposed revisions closed at the end of December 2015 and the...more
The news has been full of stories and articles concerning Coal Combustion Residuals (CCR), also referred to as coal ash. CCR became a hot topic in 2008 when a coal ash pond at a utility plant in Tennessee spilled more than 5...more
EPA Releases TSCA Assessment Documents For Flame Retardant Chemicals: On August 18, 2014, the U.S. Environmental Protection Agency (EPA) released for public comment three Problem Formulation and Initial Assessment documents...more
In this Issue: - EPA Issues SIP Call to Eliminate SSM Defense - EPA and Corps Define “Waters of The United States” - Frequent Questions: EPCRA 313 - Generators Need to be Vigilant About TCLP Sampling...more
In a final rule that was immediately effective, EPA on April 8, 2015, removed the comparable fuels exclusion and the gasification exclusion issued under the Resource Conservation and Recovery Act (RCRA). 80 Fed. Reg. 18777....more
RCRA Definition Of Solid Waste Final Rule Published In Federal Register: On January 13, 2015, the U.S. Environmental Protection Agency (EPA) published its final rule revising the Definition of Solid Waste (DSW) under the...more
After years of relative easing in its interpretation of the Resource Conservation and Recovery Act rules that govern industrial recycling, the Environmental Protection Agency is now taking a harder line. A recently issued...more
On Friday, EPA finally released its final rule regulating coal combustion residuals. Facility owners breathed a sigh of relief, as EPA chose to regulate under Subtitle D of RCRA, rather than under the cradle-to-grave...more
On December 10, 2014, EPA Administrator Gina McCarthy signed a final rule revising the Definition of Solid Waste (DSW) under the Resource Conservation and Recovery Act (RCRA). The 500 plus page-long rule should be published...more