Discarding a Square Peg into a Round Hole: Challenges of Creating a Retail Hazardous Waste Management Program

Vol. 26 No. 4

Mr. Wolff is a partner and Mr. Dombroski is an associate in the New York office of Manatt, Phelps & Phillips, LLP.

Industrial producers generally have understood for some time that their generation of hazardous waste, even in small volumes, may subject them to regulation under state and federal hazardous waste laws. Many retail businesses, on the other hand, have only recently begun to understand that their operations may also generate hazardous waste that is subject to regulation under these same laws. A major source of confusion for many retail businesses is that, counterintuitively, products that are not subject to regulation under hazardous waste laws if sold to and later discarded by a household (such as products commonly found in household medicine cabinets and laundry rooms) may be subject to regulation under hazardous waste laws when discarded by the retailer. Given the growing number and scope of products offered by typical retail establishments, including “super centers,” specialty stores, pharmacies, grocery stores, and other retailers, and given the breadth of applicable laws, most retailers have the potential to be subject to requirements regarding the management and disposal of hazardous waste.

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