RCRA

Lynn L. Bergeson, "The EPA Proposes Changes to RCRA Hazardous Waste Export and Import Regulations," Environmental Quality Management, Spring, 2016.

Prompted by a 2013 Commission for Environmental Cooperation (CEC) report on hazardous waste exports from the United States (CEC, 2013) and changes to the 2001 Organisation for Economic Cooperation and Development's (OECD) Council Decision for waste exports and imports, the United States  Environmental Protection Agency (EPA) announced on October 19, 2015, proposed changes to its regulations under the Resource Conversation and Recovery Act (RCRA) regarding the export and import of hazardous wastes from and into the United States (EPA, 2015).  EPA also proposed changes to address and respond to concerns outlined in the EPA’s Office of the Inspector General’s (OIG) July 6, 2015, report entitled “EPA Does Not Effectively Control or Monitor Imports of Hazardous Waste” (EPA OIG, 2015).  This article from the Spring, 2016, issue of Environmental Quality Management, summarizes key proposed changes.

Lynn L. Bergeson, "Worthy of Consideration," Manufacturing Today, January 3, 2016.

In October, the U.S. Environmental Protection Agency (EPA) announced proposed changes to its regulations under the Resource Conservation and Recovery Act (RCRA) regarding the export and import for recovery operations of hazardous wastes from and into the United States.

Lynn L. Bergeson, "Hazardous Waste Rules Get a Rethink," Chemical Processing, September 23, 2015.

On August 31, 2015, the U.S. Environmental Protection Agency (EPA) proposed an important rule under the Resource Conservation and Recovery Act (RCRA) that would ease the standards for healthcare facilities that dispose of hazardous waste pharmaceuticals. The proposal is of interest to all participants in the pharmaceutical value chain, from manufacturers to health care providers to end users. This column explains why.

Lynn L. Bergeson, "Electronic Hazardous Waste Manifests Rules Issued," Pollution Engineering, April 1, 2014.

On Feb. 7, 2014, EPA issued a final rule under the Resource Conservation and Recovery Act authorizing the use of electronic hazardous waste manifests. The final rule will have immediate implications for virtually all domestic manufacturers of hazardous waste. This column explains why.

Lynn L. Bergeson, "New RCRA Guidance and Checklist Issued," Pollution Engineering, January 13, 2014.

The EPA issued important guidance under the Resource Conservation and Recovery Act (RCRA) on the regulatory status of commercial chemical products (CCP). This “Legal Lookout” column explains why the guidance is important, and explains it in more detail.

Lynn L. Bergeson, "EPA Wipes Away Rule; Reusable and Disposable Solvent-contaminated Wipes Get Exclusion," Chemical Processing, August 7, 2013.

As one of the U.S. Environmental Protection Agency (EPA) Administrator Gina McCarthy’s first official acts, on July 23, 2013, the Administrator signed a final rule easing the requirements under the Resource Conservation and Recovery Act (RCRA) for solvent-contaminated rags and wipes. The rule has been long in the making and much anticipated.

Lynn L. Bergeson, "Cleaning It Up:  EPA Proposes Revisions to RCRA Definition of Solid Waste," Manufacturing Today, Fall 2011.
James V. Aidala, "Make My Day! - Registrant Gets Court To Order EPA To Cancel Their Product," Pesticide and Chemical Policy, February 4, 2011.

Reckitt Benckiser is a manufacturer of a variety of household cleaning and pesticide products, including rodenticides, sold widely under the D-Con brand. In recent years Reckitt Benckiser has formulated rodenticide products using what is known as a “second-generation” anti-coagulant, brodifacoum. The term second-generation refers to the lack of resistance in rodents, which has developed in some cases to earlier, “first-generation” anti-coagulant products, such as warfarin.

Lynn L. Bergeson, "EPA Updates IRIS Process, Again," ABA Pesticides, Chemical Regulation, and Right-to-Know Committee Newsletter, Vol. 10, No. 4, June 2009.

The U.S. Environmental Protection Agency (EPA) announced on May 21, 2009, that it has reformed the Integrated Risk Information System (IRIS), again. According to EPA, the revisions are intended to “revitalize the program and ensure its scientific quality, integrity, transparency and timeliness.” In a May 21, 2009, memorandum, Administrator Jackson states that recent changes, including procedures formalized in an April 21, 2008, memorandum, “have reduced the transparency, timeliness, and scientific integrity of the IRIS process.”


 
BERGESON & CAMPBELL, P.C.
2200 Pennsylvania Ave, N.W. Suite 100W
Washington, D.C. 20037
(202) 557-3800 • (202) 557-3836 (fax) | lawbc.com
Contact • Twitter
 
Privacy and Terms of Use | Attorney Advertising | Trademarks
©2017 Bergeson & Campbell, P.C.
All Rights Reserved.