News & Analysis as of

RCRA Comment Period

Williams Mullen

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

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

Holland & Knight LLP

EPA Proposes RCRA Corrective Action Expansions Targeting PFAS

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The 1984 Hazardous and Solid Waste Amendments amended the Resource Conservation and Recovery Act (RCRA) to add the following sections requiring corrective action for releases of hazardous waste or hazardous constituents ...more

Kelley Drye & Warren LLP

EPA Extends RCRA ​“Hazardous Constituents” Proposal to Nine PFAS

On January 31, 2024, the United States Environmental Protection Agency (“EPA” or ​“the Agency”) issued a proposal to amend Resource Conservation and Recovery Act (“RCRA”) regulations to include nine specific per- and...more

Beveridge & Diamond PC

EPA Seeks Comments on Potential Changes to the RCRA Definition of Empty Containers and Standards for Managing Used Containers

Beveridge & Diamond PC on

The U.S. Environmental Protection Agency (EPA) is considering and seeking public comment on potentially significant amendments to the hazardous waste regulations concerning the management, recycling, and disposal of drums and...more

Holland & Knight LLP

EPA Publishes Semiannual Agenda Previewing PFAS-Related Agency Actions

Holland & Knight LLP on

The U.S. Environmental Protection Agency (EPA) on July 27, 2023, published its Semiannual Regulatory Agenda, which is intended to update the public about the agency's plan to review, propose and issue regulations over the...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Coal Combustion Residuals/RCRA: Earthjustice Notice of Intent to Sue U.S. Environmental Protection Agency for Alleged Failure to...

Earthjustice on behalf of a number of environmental organizations sent a February 7th letter to United States Environmental Protection Agency (“EPA”) Administrator Andrew Wheeler styled...more

Womble Bond Dickinson

EPA Seeks Comments on Draft Interim Recommendations for Addressing Emerging Contaminants PFOA and PFOS in Groundwater

Womble Bond Dickinson on

EPA has released its Draft Interim Recommendations for Addressing Groundwater Contaminated with Perfluorooctanoic acid (PFOA) and Perfluorooctane sulfonate (PFOS) for public review and comment as part of the Agency’s PFAS...more

Holland & Hart LLP

New Proposed Changes to Ignitable Waste Regulations May Expand Definition of Hazardous Waste

Holland & Hart LLP on

On April 2, 2019, the Environmental Protection Agency (EPA) issued a proposed rule intended to modernize the regulations governing ignitable liquids hazardous waste determinations under the Resource Conservation and Recovery...more

Bergeson & Campbell, P.C.

EPA Issued Proposed Rule to Add Hazardous Waste Aerosol Cans to Universal Wastes Regulated under RCRA

On March 6, 2018, the U.S. Environmental Protection Agency (EPA) issued a proposed rule (pre-publication version available here) to add hazardous waste aerosol cans to the category of universal wastes regulated under the...more

Williams Mullen

EPA Publishes Guidance for State CCR Permitting Programs

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In April, 2015, EPA published in the Federal Register a final rule regulating the management and disposal of coal combustion residuals (CCR), commonly known as coal ash, from coal-fired power plants. Among other things, the...more

Alston & Bird

EPA Extends Comment Period for Proposed RCRA Rules

Alston & Bird on

All healthcare facilities, pharmaceutical reverse distributors and other hazardous waste generators should read the proposed rules, and each should analyze the impacts it will have on its operations and waste management...more

Butler Snow LLP

Environmental Update – Proposed Hazardous Waste Rule for Pharmaceuticals

Butler Snow LLP on

On August 31, 2015, the EPA proposed new regulations for the management of hazardous waste pharmaceuticals at healthcare facilities. First and foremost, the proposed rule prohibits the flushing of any hazardous waste...more

King & Spalding

EPA Proposes Amendments for Hazardous Waste Generators - Flexibility and Clarity May Benefit Many Stakeholders

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Generators of hazardous waste have been navigating the labyrinth of the Resource Conservation and Recovery Act (RCRA) regulatory program for more than three decades. While industries and the products they offer have seen...more

King & Spalding

EPA Proposes New Rules Regarding Waste Pharmaceuticals for Healthcare Facilities and Reverse Distributors

King & Spalding on

The Resource Conservation and Recovery Act (RCRA), which is the federal statute that regulates the generation, handling, transportation and disposal of hazardous waste, was enacted in 1976. Since that time, EPA has largely...more

Morrison & Foerster LLP

EPA’s New Draft Hazardous Waste Rules Promote Flexibility, but Devil is in the Details

On August 31, 2015, EPA released two proposed hazardous waste rules under the Resource Conservation and Recovery Act (RCRA) that will be soon be available for public comment after they are published in the Federal Register....more

Beveridge & Diamond PC

EPA Proposal to “Improve” Hazardous Waste Generator Rules Is a Mixed Bag, with Many Parts Likely to Have the Opposite Effect

On August 31, 2015, the Administrator of the U.S. Environmental Protection Agency (“EPA” or the “Agency”) signed a proposed rule designed to “improve” the long-standing requirements for generators of hazardous wastes under...more

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