In recent years, there has been a significant increase in the number of on-site inspections and enforcement activity related to retail and pharmaceutical hazardous waste. In the wake of this heightened scrutiny, the regulated community (including, for example, big box retailers, hospitals, medical clinics, and retail pharmacies) is rigorously working to maintain regulatory compliance, but the applicable RCRA regulatory scheme has proven to be the source of much confusion. Fortunately, it is clear that EPA appreciates the difficulties inherent in the current regulatory scheme, and, according to its website, EPA is set to release a proposed pharmaceutical waste management rule for public comment in March 2014.
Coal Combustion Residuals Notice of Data Availability
By Holly Hill on
Posted in Waste
Last Friday, July 26th, the Office of Management and Budget completed its review of the Coal Combustion Residuals (CCR) Notice of Data Availability (NODA). The NODA should be published in the Federal Register soon (the pre-publication version of the notice is currently available).
CCR Deadline Litigation – Status Conference Postponed Again
By Holly Hill on
Posted in Waste
This week, the Court in the Coal Combustion Residuals (CCR) deadline litigation postponed the status conference scheduled for July 26, and the conference is now set for October 11, 2013. This is the third time the court has postponed the status conference, leaving little hint of what this could mean…
Breakthrough in Gina McCarthy’s Nomination to Head EPA
Louisiana Sen. David Vitter, who had been holding up Gina McCarthy’s nomination in committee, announced on Tuesday that he won’t support a filibuster against her confirmation on the senate floor. Vitter and other members of the Committee on Environment and Public Works had indicated their dissatisfaction with EPA’s responses to five transparency questions in May.
Chemical Safety Improvement Act of 2013 Refocuses TSCA Reform
By Doug Henderson, John Johnson & Angela Levin on
Posted in Waste
In May, Senators Frank Lautenberg, D-NJ and David Vitter, R-LA introduced a bipartisan bill that would overhaul the Toxic Substances Control Act (TSCA). While the Senate has debated the concept of TSCA reform for several years now, the introduction of this bipartisan bill represents the start of a serious
conversation…
Wastewater NPDES Permits: Legal Protections
Full disclosure and strict compliance with the National Pollutant Discharge Elimination System (NPDES) permitting process under the Clean Water Act (CWA) has its benefits. That was the message delivered in a recent decision by the Federal District Court of Alaska in Alaska Community Action on Toxics v. Aurora Energy Services.