Category: Hazardous Waste Management

Montana landscape

The Montana Exceptions and a Hazardous Waste Case

In Montana v. United States (1981), the U.S. Supreme Court found that Indian tribes do not have civil or criminal jurisdiction over nontribal members within a reservation. This opinion has proven to be one of the clearest indications that Indian tribes possess no authority over lands they do not own (called non-Indian fee lands), even […]

Hazardous waste, chemical inventory, e-manifest, warehouse

Your Options Under the HazWaste e-Manifest Program

Effective October 1, 2019, through September 30, 2021, the EPA will apply new user fees in its hazardous waste (hazwaste) e-Manifest Program. Publication of the Agency’s fee memo provides an opportunity to review the different types of manifests regulated parties may use to meet their legal obligations.

Contaminated wipes, solvents

Contaminated Wipes and the ‘No-Free-Liquids’ Condition

In 2013, the EPA promulgated a final rule that removed solvent-contaminated wipes that are either cleaned and reused or disposed of from regulation under the Resource Conservation and Recovery Act (RCRA). The exclusions come with conditions, meaning the generators of these wipes must conduct certain actions to qualify. One such condition described here is that […]

Oil barrels or chemical drums stacked up

Is Your Waste Hazardous? If You Don’t Know, It Could Be Costly

“Is my waste hazardous?” This is a question common to generators of wastes in all industries. The answer to this question is essential, as it’s at the heart of the Resource Conservation and Recovery Act (RCRA) regulations for handlers of hazardous waste. Generators as well as owners/operators of treatment, storage, and disposal facilities (TSDFs) cannot […]

Avery hazardous waste label (thumb)

Complying with the EPA’s Hazardous Waste Generator Improvements Final Rule

To enhance safety and environmental protection, the EPA’s Hazardous Waste Generator Improvements Final Rule, which became effective federally last year, requires identification including the words “Hazardous Waste,” a description of the container’s hazards, and the date the accumulation started on each container. In short, generators must indicate the hazards of hazardous contents, but have flexibility […]

New Year, New Rule: Management Standards for Hazardous Waste Pharmaceuticals in Healthcare Facilities

Just before the holiday season, EPA issued its final rule for waste pharmaceuticals management. Due to the complex nature of handling waste pharmaceuticals within healthcare facilities, it became clear to EPA that these waste streams could no longer be managed with existing RCRA waste regulations. EPA previously tried to promulgate rules regarding pharmaceutical waste streams […]

Gavel, scales of justice and law books

State Court Jurisdiction Upheld by 7th Circuit in Environmental Case

Two types of jurisdiction were central to a case in which two plaintiff companies deposited hazardous waste generated in Colorado into industrial wells in Illinois. The Illinois Environmental Protection Agency (IEPA) found that the injections were conducted without the required Class I permit and brought charges against the companies before the Illinois Pollution Control Board […]