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Aaron Goldberg Quoted in BloombergBNA on Waste Generator Streamline Rule

Beveridge & Diamond, P.C., November 30, 2016

Aaron Goldberg, a Principal in Beveridge & Diamond's Washington, DC office, was quoted in a BloombergBNA article on recently-published changes to the requirements for hazardous waste generators under the Resource Conservation & Recovery Act (RCRA). 

Referring to provisions that will enable hazardous wastes from very small quantity generators to be consolidated at a large quantity generator facility controlled by the same entity, Goldberg said that the new provisions are actually more stringent than existing law, rather than less stringent as claimed by EPA.  In particular, such consolidation is already allowed, but “now they’re saying it’s no longer allowed [unless] certain, more stringent compliance requirements are met." 

Goldberg added that those compliance obligations include marking and labeling rules, storage standards and record-keeping requirements. 

Read the full article here (subscription required).

This rulemaking is one of two RCRA final rules recently promulgated.  Mr. Goldberg and others at Beveridge & Diamond prepared the following analyses of these rules: 

EPA Overhauls Rules for Hazardous Waste Generators, Imposing Substantial New Burdens on Hundreds of Thousands of Facilities in Virtually All Industries 

EPA Revises Hazardous Waste Import-Export Rules

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