In a recent webinar titled “Hazardous Waste Recycling: Uncover Cost-Effective and Legally Compliant Strategies for Your Organization’s Program,” speaker Philip Comella, Esq., head of the Environmental, Safety and Toxic Torts Group in the Chicago office of Seyfarth Shaw LLP, voiced what many have suspected: that the Resource Conservation and Recovery Act (RCRA) hazardous waste recycling regulations are, in the words of one judge, a “labyrinthian maze.”
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To ease his listeners through the confusing hazardous waste recycling requirements, Comella focused on teaching what not to do, using a case study of Marine Shale Processors. Operating an aggregate kiln in Louisiana that burned hazardous waste to produce aggregate for road fill, this company found itself on the wrong side of the law in the 1980s and 1990s by posing as a recycler producing a product when it was actually a “sham recycler” that pleaded guilty to several criminal violations and ended up as a Superfund site.