Wal-Mart generates hazardous waste. So does every other retailer or pharmacy in the country that sells everyday items such as fertilizer, bug spray, nail polish, bleach or some over the counter medications. The U.S. Environmental Protection Agency (EPA) and state governments have recently shone the spotlight on retailers’ role as hazardous waste generators, hitting these companies with tens of millions of dollars in fines based on violations of state and federal hazardous waste laws. As a result of various civil and criminal cases that culminated in May 2013, Wal-Mart is obligated to pay more than $110,000,000 in fines and other expenses to resolve violations of the federal Resource Conservation and Recovery Act (RCRA), the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) and the Clean Water Act (CWA).
Surprised that ordinary retailers can be liable under hazardous waste laws? You shouldn’t be. Gone are the days when federal and state agencies focused their hazardous waste enforcement efforts on major industrial operators. As recent cases show, retailers of common household goods must also take the steps necessary to comply with these laws or face serious civil and/or criminal consequences. This eBook discusses those laws as they apply to retailers, including some notable recent enforcement actions, and gives some guidance on what retailers can do to make sure they comply with these complex legal obligations.