Tag: RCRA

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 […]

Building window

‘Imminent and Substantial Harm’ Under RCRA Clarified by Court

A panel of the U.S. Court of Appeals for the 7th Circuit disagreed with a district court on how much harm two citizens had to have suffered from polychlorinated biphenyls (PCBs) on their property to prevail in a citizen suit brought against the party responsible for the contamination.

Pharmaceuticals

EPA’s Final Waste Pharmaceuticals Rule Effective August 21

Published in the February 22, 2019 Federal Register, EPA’s long-awaited final rule to manage hazardous waste pharmaceuticals generated by healthcare facilities (including hospitals, clinics, and retail stores with pharmacies) and reverse distributors will go into effect August 21, 2019 in EPA territories and in states that do not have an authorized Resource Conservation and Recovery […]

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 […]

Under RCRA, What Do ‘More Stringent’ and ‘Broader in Scope’ Mean?

Section 3009 of Subtitle C of the Resource Conservation and Recovery Act (RCRA) allows EPA-authorized states to promulgate hazardous waste regulations that are more stringent (MS) than counterpart federal hazardous waste (hazwaste) rules. If the EPA authorizes the MS provisions, they become part of the federal hazwaste program, which means that the EPA may enforce […]

RCRA Exemption for Airbags Issued

With the issuance of an interim exemption from the Resource Conservation and Recovery Act’s (RCRA) hazardous waste (Subtitle C) requirements, the EPA is playing its part in mitigating risks associated with the recall of Takata’s defective auto airbag inflators.