A New Way Of Looking At Solid Waste

Law360, New York (December 5, 2011, 1:33 PM EST) -- The U.S. Environmental Protection Agency has powerful investigatory and enforcement authority over materials deemed “hazardous waste” under the Resource Conservation and Recovery Act.

Pursuant to this authority, the EPA gradually has imposed numerous requirements and restrictions on the generators and transporters of hazardous waste, including requiring EPA identification numbers, the use of hazardous waste manifests identifying contaminants, and written notification of land disposal restrictions, among others.[1]

To satisfy a September 2010 settlement agreement with the Sierra Club, the EPA promulgated a new proposed rule to “revise...
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