• 12.18.17

    Pharmacies and Healthcare Facilities Await EPA's Final Pharmaceuticals Rule

    As of the time of publication, the Environmental Protection Agency (EPA) has just published its Fall Regulatory Agenda (December 14, 2017). The Regulatory Agenda establishes the agency’s rulemaking priority. In addition to foreshadowing President Trump and EPA Director Scott Pruitt’s ...

  • 01.10.17

    Hazardous Waste Update

    The past decade has seen a monumental shift in regulatory oversight of retailers’ environmental compliance programs, forcing companies to adapt compliance solutions to the myriad of hazardous waste control laws impacting the retail sector.   Historically, most enforcement has been at ...

  • 10.19.16

    Retailers Navigate Shifting Environmental Regulatory Landscape

    The past decade has witnessed a monumental shift in regulatory oversight of retailers’ environmental compliance programs. As a result, retailers have faced a crash course in the myriad hazardous waste control laws, once widely believed to not be relevant in the retail ...

  • 08.17.15

    Will NYSDEC's Audit Agreement for Retail Pharmacies Provide a Path to Increased Compliance?

    Federal and state hazardous waste handling and disposal requirements, which were established to address issues related to industrial waste generators and disposal facilities, are often a complicated and awkward fit for retail pharmacies and other "healthcare facilities." Over the past few ...

  • 11.20.14

    Pharmaceutical Hazardous Waste Regulations Bring Compliance Challenges

    Complying with the complex array of hazardous waste handling and disposal requirements under the Resource Conservation and Recovery Act ("RCRA") and its state analogues is a substantial undertaking for retail pharmacies and other "healthcare facilities." Increased federal and state enforcement ...

  • 09.30.13

    Federal Retail Hazardous Waste Reform

    Federal (and state) laws and regulations, which were initially intended to address the management and disposal of industrial hazardous waste, are often an awkward fit when applied to the management and disposal of retail "hazardous waste." For example, many common retail products sold for ...

  • 10.14.12

    California's Revised Pharmaceutical Waste Handling Law - AB 1442

    On September 28, 2012, Governor Brown announced the signing of AB 1442, which has potentially important implications for entities handling pharmaceutical items, including pharmacies, retailers, groceries, hospitals, medical clinics, and other such facilities which handle pharmaceutical and ...

  • 06.11.12

    Discarding a Square Peg into a Round Hole: Challenges of Creating a Retail Hazardous Waste ...

    Industrial producers generally have understood for some time that their generation of hazardous waste, even in small volumes, may subject them to regulation under state and federal hazardous waste laws. Many retail businesses, on the other hand, have only recently begun to understand that their ...

  • 04.23.12

    Minimizing Environmental Liabilities in Bankruptcy Reorganizations

    Neither federal bankruptcy nor federal environmental statutes address the interaction between the two areas of law. As a result, there are many questions as to how bankruptcy reorganization affects a debtor’s environmental clean-up liabilities and obligations. However, our recent experiences, ...

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