Principal Aaron Goldberg (Washington, DC) was quoted in a Bloomberg BNA 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, Aaron 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." 

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

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