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The United States Environmental Protection Agency (“EPA”) addressed in a March 22nd letter questions it was asked regarding the application of the Resource Conservation and Recovery Act (“RCRA”) to pharmaceutical hazardous...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 September 30, 2020, the Washington State Department of Ecology (Ecology) adopted updates to its Dangerous Waste Regulations, Chapter 173-303 WAC. These updates go into effect on October 31, 2020. The updated...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
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
On February 22, 2019, the Environmental Protection Agency (EPA) published its final rule revising management standards for hazardous waste pharmaceuticals, which will take effect August 2019. Healthcare facilities that...more
I undertook a presentation on April 17th at the Arkansas Environmental Federation Regulated Waste Seminar titled: Solid and Hazardous Waste Judicial/Regulatory Developments: 2018 – 2019 - The discussion addressed...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
• The U.S. Environmental Protection Agency (EPA) has published a new rule to address the handling, storage, transportation and disposal of hazardous waste pharmaceuticals by healthcare facilities and reverse distributors. •...more
The U.S. Environmental Protection Agency (“EPA”) recently issued new regulations for managing pharmaceutical waste under the Resource Conservation and Recovery Act (“RCRA”). The rules specify new requirements for hazardous...more
Health care facilities that provide a host of health care-related services or distribute, sell, or dispense pharmaceuticals will need to learn a whole new set of regulations thanks to a finalized new rule promulgated by the...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
On December 11, 2018, the Acting Administrator of the U.S. Environmental Protection Agency (EPA or "the Agency”) signed a final rule establishing special management standards for pharmaceutical wastes that are classified as...more
The U.S. Environmental Protection Agency (EPA) will soon publish new rules that provide tailored standards for handling hazardous-waste pharmaceuticals in the health care sector. The rules streamline the requirements for the...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
On December 12, 2018, the EPA released its long-awaited Management for Hazardous Waste Pharmaceuticals Rule. The EPA addressed industry concerns by amending the hazardous waste listing for nicotine to exclude nicotine...more
Barnes Johnson, Director of the United States Environmental Protection Agency (“EPA”) Office of Resource Conservation and Recovery (“RCRA”) authored a September 11th memorandum titled: Management of Household...more
A new rule proposed by the EPA to take effect in July 2018 would redefine pharmaceutical waste under the Resource Conservation and Recovery Act (RCRA), fundamentally altering how the pharmaceutical supply chain currently...more
The United States Environmental Protection Agency (“EPA”) and Gastroenterology Consultants of San Antonio, P.A. (“GCS”) entered into a Consent Agreement and Final Order (“CA”) addressing alleged Resource Conservation and...more
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...more
On September 12, 2016, the U.S. Environmental Protection Agency (EPA) issued its Strategy for Addressing the Retail Sector under RCRA’s Regulatory Framework. As part of this strategy, EPA will finalize the Resource...more
The Environmental Protection Agency (EPA) has promulgated its proposed regulation of “hazardous waste pharmaceuticals,” i.e., pharmaceutical residues discarded from health care facilities which also meet EPA’s long-standing...more
All healthcare facilities, pharmaceutical reverse distributors and other hazardous waste generators should read the proposed rules, and each should analyze the impacts it will have on its operations and waste management...more
On August 31, 2015, the EPA proposed new regulations for the management of hazardous waste pharmaceuticals at healthcare facilities. First and foremost, the proposed rule prohibits the flushing of any hazardous waste...more
On September 25, 2015, the United States Environmental Protection Agency published a proposed rule concerning “Management Standards for Hazardous Waste Pharmaceuticals”. Under the proposed rule, the term “healthcare...more