The proposed rules would expand the RCRA Corrective Action regime to PFAS and potentially other emerging contaminants. They may complicate ongoing compliance efforts as well as lead to significant value chain impacts.
By Gary P. Gengel, Julia A. Hatcher, Thomas C. Pearce, and Guy Jack Mathews
The Resource Conversation and Recovery Act (RCRA) mandates a two-part “corrective action” regime:
- Permits for any “solid waste management unit” (SWMU) at a “treatment, storage or disposal facility” (TSDF) must require
On May 10, 2019, following two weeks of negotiations involving 1,400 delegates, at the Conferences of Parties to the Basel, Rotterdam and Stockholm Conventions, it was agreed to extend the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal (the Basel Convention) to include plastic waste (as well as making certain changes to the Rotterdam and Stockholm Conventions). The framework regarding the Basel Convention will look to implement a transparent and traceable system for the export and import of most plastic wastes under which exporting states must now obtain prior written consent from importing states.