On January 3, 2018, the Environmental Protection Agency (EPA) published the User Fees for the Electronic Hazardous Waste Manifest System and Amendments to Manifest Regulations Final Rule (“User Fee Rule” or “Rule”) in the Federal Register (83 Federal Register 420).  While the User Fee Rule does not set e-Manifest user fees, it gives EPA authority to establish user fees and establishes the methodology for EPA to do so.  The Rule becomes effective June 30, 2018.

On October 25, 2017, EPA Region 6 announced a settlement with Macy’s department stores for alleged violations of hazardous waste regulations.  In the press release, EPA alleged that Macy’s generated thousands of pounds of hazardous waste between 2012 – 2015 and qualified as a small-quantity generator but failed to…

On February 24, 2017, industry groups challenged the final Hazardous Waste Generator Improvements Rule (“Final Rule”) in the Court of Appeals for the D.C. Circuit.  The long-anticipated Final Rule was published in the Federal Register on November 28, 2016 (81 Fed. Reg. 85732).  Pursuant to Resource Conservation and Recovery Act (“RCRA”) section 7006, petitioners have ninety days from that date to challenge the rule in the D.C. Circuit.  Because the ninety-day deadline to challenge the rule expired on Monday, February 27, 2017, no more challenges may be filed.  A previous discussion of the Final Rule and its potential impacts can be found here.