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EPA Expands RCRA Hazardous Waste Restrictions to a Broader Range of ‘Pharmaceuticals’ Including Dietary Supplements

By Tim Swickard on July 29, 2019
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If you are currently disposing of pharmaceuticals, including dietary supplements, into the dumpster or down the drain, you may want to reconsider that practice. New regulations promulgated by the Environmental Protection Agency (EPA) under the Resource Conservation and Recovery Act (RCRA) impact how health care facilities must dispose of unused pharmaceuticals. The new regulations treat some dietary supplements as pharmaceuticals and therefore regulate them as hazardous waste. Additionally, as of Aug. 21, 2019, health care facilities may be prohibited from disposing of pharmaceuticals and dietary supplements into the sewer, etc. This is in addition to RCRA already prohibiting disposal into the garbage or in some instances by recycling. Noncompliance comes with hefty fines.

  • Does your company qualify as a health care facility?
  • Do your products qualify as pharmaceuticals?
  • Is your product a hazardous waste pharmaceutical?
  • Penalties and implementation

Click here for the full GT Alert.

Photo of Tim Swickard Tim Swickard

Tim Swickard focuses his practice on federal and state environmental regulatory compliance and litigation, real estate development, land use entitlement, environmental compliance, hazardous waste, and water law. He represents recycling, environmental cleanup, transportation industry businesses, commercial and residential developers, Indian Nations, public agencies,

…

Tim Swickard focuses his practice on federal and state environmental regulatory compliance and litigation, real estate development, land use entitlement, environmental compliance, hazardous waste, and water law. He represents recycling, environmental cleanup, transportation industry businesses, commercial and residential developers, Indian Nations, public agencies, and landowners. Tim previously served as the director and chief counsel for Cal/EPA Department of Toxic Substances Control under Governor Arnold Schwarzenegger.

Tim counsels clients on a wide array of topics related to environmental and regulatory law, including USEPA, USCOE, Cal/EPA, USFSW, CDFW, FDA, USDA, and CDFA. He also represents clients in OSHA Workplace Health and Safety facility regulatory compliance and enforcement defense, permitting and licensing, transportation, and storage.

Tim represents clients in brownfields development and other fields where energy law, real estate law, and governmental regulation overlap, such as CEQA, NEPA, wetlands, endangered species, transportation law, natural resource damages, air quality, greenhouse gas emissions, contaminated site cleanup cost allocation, mining, timber harvesting, agricultural law, and legislative and regulatory advocacy.

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  • Posted in:
    Environmental and Climate
  • Blog:
    E2 Law Blog
  • Organization:
    Greenberg Traurig, LLP
  • Article: View Original Source

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