EPA’s Final Hazardous Waste Pharmaceuticals Rule Has Significant Implications for Pharmaceuticals and Product Recalls

EPA’s Final Hazardous Waste Pharmaceuticals Rule Has Significant Implications for Pharmaceuticals and Product Recalls

January 8, 2019, Covington Alert

Under the Resource Conservation and Recovery Act (“RCRA”), waste deemed “hazardous waste” is subject to onerous regulatory requirements, including: a 90-day storage limitation, shipment to a RCRA-permitted facility for disposal, and tracking from generation to disposal via a manifest system.