Today, August 21, 2019, EPA’s Final Management Standards for Hazardous Waste Pharmaceuticals takes effect federally.  The sewer ban component of the new rule applies in all states.  Healthcare facilities are now prohibited from flushing hazardous waste pharmaceuticals, including DEA controlled substances and “pharmaceutical wastage” that are hazardous waste.  This sewering ban may drive many facilities to stop flushing pharmaceuticals entirely (even those that are not hazardous waste), given how complicated it is in practice for healthcare provides to determine which drugs are hazardous [...]R ..read more

In late 2018, the California Air Resources Control Board (CARB) proposed a new statewide reporting program for air quality of both criteria pollutants and toxic air contaminants. The new reporting rules will apply to more than 50,000 businesses in California, including auto body shops, retail gas stations, print shops, dry cleaners, and facilities with backup diesel generators or emergency fire pumps among may others. Many of these businesses may need to hire engineers and consultants to assist in calculating the emissions and in the preparation of the new reporting as early as January 2020. T ..read more

The EPA and Department of the Army submitted their revised proposal to amend the definition of “waters of the United States” for purposes of establishing federal jurisdiction under the Clean Water Act. The public comment period on the revised proposal has opened and will close on April 15, 2019. The agencies will host a two-day public hearing on February 27 and 28, 2019. It appears the agencies intend to finalize the new rule this year. The proposed waters of the United States (WOTUS) rule is a result of the February 2017 presidential Executive Order that directed the agencies to review [...]R ..read more