News & Analysis as of May 1, 2025

Advanced Notice of Proposed Rulemaking (ANPRM) › Hazardous Waste

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Drumming Up a Change? EPA’s Review of the RCRA “Empties” Rule and Its Impact on Generators and the Drum Reconditioning Industry

Williams Mullen on 4/10/2025

EPA recently initiated a rulemaking process aimed at reviewing how empty industrial drums are regulated under the Resource Conservation and Recovery Act (RCRA). This is a move which could have significant implications for...more

Reconditioning/Used Drum Management: American Coatings Association Comments Addressing U.S. Environmental Protection Agency...

Mitchell, Williams, Selig, Gates & Woodyard,... on 1/15/2024

The American Coatings Association (“ACA”) submitted comments to the United States Environmental Protection Agency (“EPA”) on November 22nd addressing the following Advanced Notice of Proposed Rulemaking (“ANPR”): Used...more

Reconditioning/Used Drum Management: Cement Kiln Recycling Coalition Comments Addressing U.S. Environmental Protection Agency...

Mitchell, Williams, Selig, Gates & Woodyard,... on 12/18/2023

The Cement Kiln Recycling Coalition (“CKRC”) submitted November 21st comments to the United States Environmental Protection Agency (EPA”) addressing the following Advance Notice of Proposed Rulemaking (“ANPR”) titled: ...more

Reconditioning/Used Drum Management: ASTSWMO Comments Addressing U.S. Environmental Protection Agency Advance Notice of Proposed...

Mitchell, Williams, Selig, Gates & Woodyard,... on 12/4/2023

The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) submitted comments to the United States Environmental Protection Agency (“EPA”) on November 22 addressing the following Advance Notice of...more

Reconditioning/Used Drum Management: Alliance for Chemical Distribution Comments Addressing U.S. Environmental Protection Agency...

Mitchell, Williams, Selig, Gates & Woodyard,... on 11/27/2023

The Alliance for Chemical Distribution (“ACD”) submitted comments to the United States Environmental Protection Agency (“EPA”) on November 17th addressing the following Advance Notice of Proposed Rulemaking (“ANPR”): ...more

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