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Category: Regulatory Issues

FDA Updates Guidance on Ethanol for Use in Hand Sanitizers

September 1, 2020 Todd Pencarinha Blog, Ethanol, Hand Sanitizers, Regulatory Issues

In light of the ongoing COVID-19 pandemic, on August 7th, 2020 the FDA once again updated its guidance for its[…]

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EPA Issues Revised Final Rule to 2015 RCRA Update

June 15, 2018 Todd Pencarinha Blog, Regulatory Issues, Waste Recycling

On July 7, 2017, the D.C. Circuit Court of Appeals struck down portions of the US Environmental Protection Agency’s Definition[…]

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DC Circuit Court Strikes Down Parts of 2015 RCRA Update

August 4, 2017 Todd Pencarinha Blog, Regulatory Issues, Waste Recycling

On July 7, 2017, the D.C. Circuit Court of Appeals struck down portions of the US Environmental Protection Agency’s Definition[…]

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D.C. District Court confirms Invalidity of EPA’s prior Rules on “Inherently Waste-like Materials”

August 2, 2017 Todd Pencarinha Blog, Regulatory Issues, Waste Recycling

Recently, the United States Court of Appeals for the District of Columbia Circuit ruled on the EPA’s 2015 Final Rule[…]

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D.C. Circuit Court Strikes down Provisions of EPA’s 2015 Changes to the Definition of Solid Waste

July 28, 2017 Todd Pencarinha Blog, Regulatory Issues, Waste Recycling

On July 7, 2017 the U.S. Court of Appeals for the District of Columbia struck down provisions of the the[…]

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FAQ: Can my Hazardous Secondary Materials be distilled before being beneficially used?

July 5, 2017 Todd Pencarinha Blog, Regulatory Issues, Waste Recycling

Generally hazardous secondary materials can not be distilled without being considered a hazardous waste and requiring shipment on a hazardous[…]

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FAQ: Can my Hazardous Secondary Materials be applied to the land?

July 5, 2017 Todd Pencarinha Blog, Regulatory Issues, Waste Recycling

The answer is “yes”.  Environmental professionals often believe that land application is not acceptable for any type of hazardous secondary[…]

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FAQ: Do I need a RCRA Part B permit to recycle my hazardous chemicals on-site?

June 23, 2017 Todd Pencarinha Blog, Regulatory Issues, Waste Recycling

No.  Under 40 CFR 261.4(a)(23) hazardous secondary materials may be reclaimed without a RCRA Part B permit, so long as[…]

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FAQ: If I want to recycle hazardous chemicals off-site, do they have to go to a RCRA Part B permitted facility?

June 23, 2017 Todd Pencarinha Blog, Regulatory Issues, Waste Recycling

No.  Under 40 CFR 261.4(a)(24) hazardous secondary materials may be reclaimed off-site at facilities that do not posses a RCRA[…]

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New Changes to Requirements for Hazardous Waste Generators now in Effect

June 4, 2017 Todd Pencarinha Blog, Regulatory Issues, Waste Recycling

We previously did a series of blogs to explain the upcoming changes to RCRA regulations that will impact generators of[…]

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