In light of the ongoing COVID-19 pandemic, on August 7th, 2020 the FDA once again updated its guidance for its[…]
Read moreCategory: Regulatory Issues
EPA Issues Revised Final Rule to 2015 RCRA Update
On July 7, 2017, the D.C. Circuit Court of Appeals struck down portions of the US Environmental Protection Agency’s Definition[…]
Read moreDC Circuit Court Strikes Down Parts of 2015 RCRA Update
On July 7, 2017, the D.C. Circuit Court of Appeals struck down portions of the US Environmental Protection Agency’s Definition[…]
Read moreD.C. District Court confirms Invalidity of EPA’s prior Rules on “Inherently Waste-like Materials”
Recently, the United States Court of Appeals for the District of Columbia Circuit ruled on the EPA’s 2015 Final Rule[…]
Read moreD.C. Circuit Court Strikes down Provisions of EPA’s 2015 Changes to the Definition of Solid Waste
On July 7, 2017 the U.S. Court of Appeals for the District of Columbia struck down provisions of the the[…]
Read moreFAQ: Can my Hazardous Secondary Materials be distilled before being beneficially used?
Generally hazardous secondary materials cannot be distilled without being considered a hazardous waste and requiring shipment on a hazardous waste[…]
Read moreFAQ: Can Land Application of Hazardous Secondary Materials be Legitimate?
The answer is “yes”. Environmental professionals often believe that land application is not acceptable for any type of hazardous secondary[…]
Read moreFAQ: Do I need a RCRA Part B permit to recycle my hazardous chemicals on-site?
No. Under 40 CFR 261.4(a)(23) hazardous secondary materials may be reclaimed without a RCRA Part B permit, so long as[…]
Read moreFAQ: If I want to recycle hazardous chemicals off-site, do they have to go to a RCRA Part B permitted facility?
No. Under 40 CFR 261.4(a)(24) hazardous secondary materials may be reclaimed off-site at facilities that do not posses a RCRA[…]
Read moreNew Changes to Requirements for Hazardous Waste Generators now in Effect
We previously did a series of blogs to explain the upcoming changes to RCRA regulations that will impact generators of[…]
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