Category: Hazardous and Solid Waste

Countdown to the e-Manifest System Launch!

June 30, 2018, marks the launch date of the U.S. Environmental Protection Agency’s (EPA) national e-Manifest system in all 50 states. Revised regulations are in place, the new system has been tested by users, and countless questions have been asked of the EPA, primarily regarding the mechanics of how to register for and navigate through […]


EPA Moves to Implement HSM Orders from D.C. Circuit

In a final rule promulgated without a prior proposal, the EPA is revising regulations associated with the definition of solid waste under the Resource Conservation and Recovery Act (RCRA). The revisions apply specifically to rules the Agency issued in 2008 and 2015, which addressed the conditions under which hazardous secondary materials (HSMs) are legitimately recycled.

The E-Manifest System and How It Affects You

After more than 6 years of developing new electronic manifest (e-manifest) regulations and the technology to make electronic submission possible, the EPA is set to launch the national e-manifest system on June 30th. The Final Rule, issued on January 3, 2018, is one of the last steps in the implementation of the e-manifest system.  It […]

Aerosol cans

EPA Looking to Make Aerosol Cans Universal Waste

In a much anticipated development, the EPA is proposing to add aerosol cans to the federal universal waste program. If finalized, the addition would simplify waste handling for many sectors and provide particular relief to the retail sector, which currently must manage at least some of the vast population of aerosol cans under the full […]

EPA Proposes Changes to Coal Combustion Rule

The EPA has issued the first of two proposals that together will lessen the stringency of the Obama administration’s 2015 rule governing the disposal of coal combustion residuals (CCRs) generated by electric utilities. The Phase One proposal comprises a dozen changes, some that result from a remand of parts of the 2015 rule by the […]

Do I Need to Install a Leachate Collection System?

Q. Is installing a leachate collection system required by the EPA for a solid waste landfill? A. It is most likely that either the EPA or a state environmental agency will require a leachate collection system in a solid waste landfill.

The Definition of Solid Waste Rule Changes … Again

When the U.S. Environmental Protection Agency (EPA) issues a final hazardous waste regulation, the regulated community safely assumes that’s that and all that now needs to be done is to accurately decipher the implications of the rule and follow its requirements. But that is not always the case, especially when litigation is involved and a […]