On September 12, 2016, the EPA issued its Strategy for Addressing the Retail Sector under RCRA’s Regulatory Framework (Strategy Document), which addresses growing concerns about the application of federal hazardous waste regulations to pharmacies and retail operations. The Strategy Document takes into account practices common to pharmacies (e.g., reverse distribution) that present unique compliance issues which are of significant concern given EPA’s enforcement actions during the past few years over similar practices at retail operations like Whole Foods and Wal-Mart.

Husch Blackwell attorneys, Megan Caldwell, Megan McLean and Jonathan Waldron provide the background, regulatory framework and what the proposed regulations could mean to you in a recent legal alert.