Articles

12.01.17

The Overlooked Importance of Fresh Environmental Diligence

The federal Comprehensive Environmental Response Compensation & Liability Act and its state analogues generally take a very expansive view of liability for environmental contamination and include owners and operators (e.g., lessees) as potentially liable parties without regard to whether such ...


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 ...


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, ...