The Federal Electronics Challenge Presents. Potential Liabilities of Electronic Waste

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "The Federal Electronics Challenge Presents. Potential Liabilities of Electronic Waste"

Transcription

1 The Federal Electronics Challenge Presents Potential Liabilities of Electronic Waste 1

2 Agenda Introduction to two environmental laws Liability laws for information Two examples of electronic waste dumping What can be done to reduce liability 2

3 CERCLA Comprehensive Environmental Response, Compensation, and Liability Act Also known as Superfund Addresses abandoned and closed hazardous waste sites Uses administrative orders that requires one or more parties to conduct the cleanup Holds those responsible for the release of hazardous waste liable for the cleanup costs Establishes a fund for cleanup when responsible parties can not be identified Full text of CERCLA: 3

4 CERCLA Liability Is strict and joint and several Any party that ever sent any waste to the facility is potentially fully liable for cleanup The liability is applied regardless of what was sent, and what the contamination is A party can not be released from this liability May require cleanup costs be paid years, or decades, later Citizen suites can also be used to collect costs 4

5 How a generator could become liable for cleanup costs If a generator sends electronics to a recycler that releases toxins and goes out of business, then anyone who sent material to the recycler could be liable for cleanup costs There is always the possibility of liability if a recycler mismanages material and has a release of toxic materials If a facility disposes of, or arranges for disposal of, electronics in a landfill or other disposal site there is the risk of CERCLA liability if the site begins to release hazardous substances. 5

6 RCRA Resource Conservation and Recovery Act Provides cradle to grave hazardous waste management authority Includes generation, treatment, and storage of hazardous waste Regulates active facilities EPA ID numbers are issued to facilities that handle waste; it is not a certification of their work Full text of RCRA: 6

7 RCRA Liability Liability applies to the parties responsible for the facility in the event of a release CERCLA generally defers regulatory control to RCRA An EPA identification number is not an assurance of good environmental practice Allows for monitoring the volume of waste generated Prevents registered generators from dealing with non-registered parties It is not a certification of responsible management by the EPA 7

8 RCRA Liability Generally, a facility that disposes of over 220 lbs. of hazardous waste a month becomes a small quantity generator. This is about 8 CRT containing monitors This weight is the total weight of the hazardous electronic equipment, not just the hazardous component Local hazardous waste rules may be stricter than federal rules. Enforcement may be by: State or local agency EPA Citizen suit provisions of RCRA 8

9 Liability in regards to the sale of electronics Generally, selling a useful product releases the seller from liability However, if usable products are sold with unusable materials this could be considered arranging for disposal If the buyer improperly manages the unusable material there is potential for the seller to be liable 9

10 State to State Variation CERCLA and RCRA are two federal laws covering hazardous waste management States are required to adopt these standards, or create their own Any state specific standards must be stricter than the federal rules Contact your state and local officials for information about any local rules For individual situations, contact your facility s legal counsel. 10

11 Questions? 11

12 Management of Sensitive Information Regulatory requirements are in place that mandate the protection of confidential and privileged information Financial Services Modernization Act of 1999 (Gramm-Leach-Biley Act) imposes requirements on the broad definition of financial institutions Civil and criminal penalties can be enforced 12

13 Management of Sensitive Information Medical Privacy Regulations (HIPPA) Provides for protection of medical records and personal health information Both criminal and civil penalties can apply Sensitive information Beware of what information may be on disk drives or removable media If unable to verify the sensitivity of the information contained on the media do not release it, and seek advice from the material s originator 13

14 Questions? 14

15 Illegal dumping In some states the waste generator can be held responsible if waste is illegally dumped. These laws have been used to stop dumping, or recover cleanup costs as shown in the following example 15

16 Example: A Sham Recycler Abandons Electronic Waste In Minnesota a recycler collected electronic waste from schools, businesses, and not-for-profits The recycler retrieved components of value and abandoned low value materials 16

17 Example: A Sham Recycler Abandons Electronic Waste Many groups had paid the recycler thinking that he would properly recycle the material Other groups had donated the material to a third party that sent the equipment to the recycler for processing No one expected to ever hear about the equipment again 17

18 Example: A Sham Recycler Abandons Electronic Waste There was a judgment against the recycler: clean it up in five months or get 90 days in jail. Because the landlord is losing rent she has taken it upon herself to clean up the waste. To recover her cleanup costs, potentially over $100,000; she may sue the waste generators. Since the recycler abandoned the material and stopped paying rent over a year ago, the landlord may attempt to recover lost rent from the generators. 18

19 A Federal Enforcement Example In 2000 the Department of Health and Human Services (DHHS) in Boston was caught placing electronic equipment in dumpsters for disposal. This is a violation of state law and RCRA Massachusetts has a landfill ban for CRTs They attempted to dispose of over 220 lbs. of hazardous waste 19

20 A Federal Enforcement Example EPA was able to issue a notice of violation (NOV) and impounded the dumpster the same day The potential maximum fine was $27,500 per violation EPA s NOV required DHHS to remove their waste from the dumpster and manage it correctly DHHS sent the material to a local recycler and no further action was taken by EPA 20

21 Questions? 21

22 How to Minimize Liability Perform a proper due diligence of recyclers Ask recycles where their material goes and about their experience recycling. The end-of-life call will cover this more in-depth Purchase equipment with a reduced toxics content Extend the life of equipment by upgrading it Each facility or agency should maintain responsibility for donation or recycling of its electronic waste, and not pass it off to other agencies to manage 22

23 How to Minimize Liability Only sell or donate working equipment Responsibly manage unusable materials - RECYCLE Do not assume that a buyer will properly handle equipment that parts were taken from for repair Be tough when evaluating equipment don t pass problem equipment on to others Selling or donating unusable equipment is unfair, and may make it difficult to find groups to take working equipment in the future. 23

24 How to Minimize Liability Work with the recipients of donations so they know how to, and will, properly manage EOL equipment Educate them about the issues of electronic waste Offer them lists of recyclers Discuss how to facilitate recycling Donating group takes back the equipment for recycling Allowing recipients to make use of existing recycling services contracts Other options? 24

25 How to Minimize Liability Leasing Is an arrangement that provides certain services, or equipment, for a set period of time. The lessee does not take ownership of the equipment, and returns the equipment to the lessor at the end of the lease In most situations this puts the burden of disposal onto the lessor Other effects of leasing might be: Encouraging manufactures to increase the ease in which equipment can be recycled Decrease the level of toxins in electronics 25

26 How to Minimize Liability The FEC has more information at: FEC Checklist for recycling services FEC Federal Property Reuse Program 26

27 Questions? 27

28 Contact Us Christopher Kent (US EPA, Headquarters) Viccy Salazar, (US EPA, Region 10) Chris Newman (US EPA, Region 5) Adrienne Priselac (US EPA, Region 9)

Before beginning any construction or demolition activities at your construction site,

Before beginning any construction or demolition activities at your construction site, VII. Hazardous Substances (Superfund Liability) Requirements for Construction Activities Before beginning any construction or demolition activities at your construction site, you should evaluate the site

More information

Learning Objectives. Solid and Hazardous Wastes. Definitions. Statement of Problem. Gene D. Schroder PhD

Learning Objectives. Solid and Hazardous Wastes. Definitions. Statement of Problem. Gene D. Schroder PhD Learning Objectives Solid and Hazardous Wastes Gene D. Schroder PhD To understand the sources of solid and hazardous wastes. To understand methods of solid waste disposal. To evaluate the health risks

More information

Environmental laws have been enacted to protect natural resources and the public health. A number

Environmental laws have been enacted to protect natural resources and the public health. A number Workers Whistleblower Protection Under Seven Federal Environmental Laws Protecting Workers Who Exercise Rights PWWER A PROJECT OF THE NATIONAL Committees for Occupational Safety and Health NETWORK FACTSHEET

More information

Site Cleanup in Connecticut

Site Cleanup in Connecticut Site Cleanup in Connecticut Taking the Mystery Out of Dealing with Contaminated Property in Connecticut: Information for Property Owners, Buyers, Sellers, Attorneys, Bankers, Insurance Representatives

More information

CONTRACTOR ENVIRONMENTAL LIABILITY 101. Violation of environmental laws may result in fine or imprisonment or both.

CONTRACTOR ENVIRONMENTAL LIABILITY 101. Violation of environmental laws may result in fine or imprisonment or both. CONTRACTOR ENVIRONMENTAL LIABILITY 101 Violation of environmental laws may result in fine or imprisonment or both. To avoid potential liability, contractors must be aware of the requirements of the various

More information

U.S. EPA s Office of Criminal Enforcement, Forensics and Training

U.S. EPA s Office of Criminal Enforcement, Forensics and Training U.S. EPA s Office of Criminal Enforcement, Forensics and Training United States Environmental Protection Agency Protecting Human Health and the Environment Who We Are in OCEFT A team of 350 professionals

More information

Environmental Protection Agency Criminal Investigation Division. Special Agent Benjamin Carr Special Agent Christopher Anderson

Environmental Protection Agency Criminal Investigation Division. Special Agent Benjamin Carr Special Agent Christopher Anderson Environmental Protection Agency Criminal Investigation Division Special Agent Benjamin Carr Special Agent Christopher Anderson Title 18 Federal Criminal Code Criminal Enforcement Title 18 Federal Criminal

More information

CERCLA Liability and Local Government Acquisitions

CERCLA Liability and Local Government Acquisitions CERCLA Liability and Local Government Acquisitions Helena Healy and Cecilia De Robertis U.S. Environmental Protection Agency Office of Site Remediation Enforcement Working Together EPA wants to help local

More information

WHISTLEBLOWING AND CONDUCTING INVESTIGATIONS. Eileen P. Kennedy Berliner Cohen

WHISTLEBLOWING AND CONDUCTING INVESTIGATIONS. Eileen P. Kennedy Berliner Cohen WHISTLEBLOWING AND CONDUCTING INVESTIGATIONS Eileen P. Kennedy Berliner Cohen 1 Topics I. New Laws Protecting Whistleblowers. II. III. IV. Other Anti-Retaliation and Whistleblower Protections. Discipline

More information

Citizen Suit Provisions. Restoring Hazardous Landscapes! Science, Justice, and Law! Declaration of National Environmental Policy

Citizen Suit Provisions. Restoring Hazardous Landscapes! Science, Justice, and Law! Declaration of National Environmental Policy Declaration of National Environmental Policy Restoring Hazardous Landscapes! Science, Justice, and Law! Professor John Wargo! PLSC 215b/EVST 255b Environmental Politics and Law Lecture 7: February 4, 2010

More information

Building an ITAD Program:

Building an ITAD Program: Building an ITAD Program: What Your Company Needs To Know By: Integrated Communications & Technologies Contents 3 4 6 7 8 9 Introduction Understanding The Concepts of IT Asset Disposition Evaluating by

More information

PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION BUREAU OF WASTE MANAGEMENT

PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION BUREAU OF WASTE MANAGEMENT PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION BUREAU OF WASTE MANAGEMENT DOCUMENT NUMBER: 250-4000-004 TITLE: Program Implementation Guidance EFFECTIVE DATE: September 17, 2005 AUTHORITY: The Solid

More information

DEVELOPMENT DUE DILIGENCE CHECKLIST

DEVELOPMENT DUE DILIGENCE CHECKLIST DEVELOPMENT DUE DILIGENCE CHECKLIST A. Title Condition. 1. Preliminary Title Reports. A current preliminary title report ( PTR ) for the Real Property. 2. Copies of Exceptions to Title. Copies of all documents

More information

Environmental Law 101 for Business Lawyers

Environmental Law 101 for Business Lawyers 16-004 Environmental Law 101 for Business Lawyers David E. Nash McMahon DeGulis LLP Cleveland, Ohio ENVIRONMENTAL LAW 101 FOR BUSINESS LAWYERS 2016 OSBA Business Law Conference May 23, 2016 David E. Nash

More information

Chapter 10. Overview of Federal Laws and Regulations Governing Incineration

Chapter 10. Overview of Federal Laws and Regulations Governing Incineration Chapter 10 Overview of Federal Laws and Regulations Governing Incineration Contents Land-Based Incineration.......................... Ocean Incineration.............................. Statutes Governing

More information

Environmental Concerns in Real Estate Transactions by Ann R. Barker Baker Petrolite Corporation. Real Estate Transactions and Issues

Environmental Concerns in Real Estate Transactions by Ann R. Barker Baker Petrolite Corporation. Real Estate Transactions and Issues Environmental Concerns in Real Estate Transactions by Ann R. Barker Baker Petrolite Corporation Real Estate Transactions and Issues Background Since the early 1980s, federal and state legislation has been

More information

I. PURPOSE AND SCOPE. The EPA Region 4 and KYDEP agree to exercise their respective legal authorities in order to:

I. PURPOSE AND SCOPE. The EPA Region 4 and KYDEP agree to exercise their respective legal authorities in order to: Voluntary Remediation Program Memorandum of Agreement Between the U.S. Environmental Protection Agency, Region 4 and the Kentucky Department for Environmental Protection This Memorandum of Agreement (MOA)

More information

BANKRUPTCY AND ENVIRONMENTAL COMPLIANCE AND LIABILITY. New Hampshire Waste Management Seminar Nov. 2, 2015 -------------- Peter C.L.

BANKRUPTCY AND ENVIRONMENTAL COMPLIANCE AND LIABILITY. New Hampshire Waste Management Seminar Nov. 2, 2015 -------------- Peter C.L. BANKRUPTCY AND ENVIRONMENTAL COMPLIANCE AND LIABILITY New Hampshire Waste Management Seminar Nov. 2, 2015 -------------- Peter C.L. Roth WHAT IS BANKRUPTCY? A process in which individuals and entities

More information

ENVIRONMENTAL COSTS ON GOVERNMENT CONTRACTS

ENVIRONMENTAL COSTS ON GOVERNMENT CONTRACTS ENVIRONMENTAL COSTS ON GOVERNMENT CONTRACTS Jonathan A. DeMella Traeger Machetanz Lisa M. Marchese Government Contracts Counseling & Litigation Practice Group Risk Mitigation & Cost Recovery Strategies

More information

Asset Management Equipment Redeployment And Termination Services. A Service Offering From Data Center Assistance Group, Inc.

Asset Management Equipment Redeployment And Termination Services. A Service Offering From Data Center Assistance Group, Inc. DCAG Data Center Assistance Group, Inc. Revision Date: 5/20/2013 Asset Management Redeployment And Termination Services A Service Offering From Data Center Assistance Group, Inc. (DCAG) Prepared by: Thomas

More information

Joseph G. Maternowski Shareholder

Joseph G. Maternowski Shareholder Joseph G. Maternowski Shareholder Practicing in the areas of Environmental, Administrative, Litigation, Business and Real Estate Law. Positions Held: Shareholder, Hessian & McKasy, P.A., January 2012 to

More information

WASTE MANAGEMENT PLAN CERTIFICATION AND COMPLIANCE FORM (GSFA Residential Energy Retrofit Program)

WASTE MANAGEMENT PLAN CERTIFICATION AND COMPLIANCE FORM (GSFA Residential Energy Retrofit Program) Golden State Finance Authority (GSFA) 1215 K Street, Suite 1650 Sacramento, California 95814 Phone: (855) 740-8422 Fax: (916) 444-3219 www.gsfahome.org WASTE MANAGEMENT PLAN CERTIFICATION AND COMPLIANCE

More information

Harvard University. Hazardous Waste Program Overview

Harvard University. Hazardous Waste Program Overview Harvard University Hazardous Waste Program Overview Outline Cradle-to-grave approach Hazardous Waste related laws RCRA inspections at Universities Roles and Responsibilities Sink Disposal Labelling requirements

More information

Environmental Health and Safety Management Plan

Environmental Health and Safety Management Plan Introduction In today s highly competitive industry, the advancement of technology and processes has brought about an increased concern for environmental, health and safety issues facing the business community.

More information

Compliance Bulletin Hazardous Waste Lighting Waste reviewed/revised March 2012

Compliance Bulletin Hazardous Waste Lighting Waste reviewed/revised March 2012 Lamp Wastes Many commonly used lamps contain small amounts of mercury and other metals. Such lamps include fluorescent, compact fluorescent, high-pressure sodium, mercury vapor and metal halide lamps.

More information

INSURANCE AND POLLUTION PREVENTION

INSURANCE AND POLLUTION PREVENTION INSURANCE AND POLLUTION PREVENTION Publication #99-439 Environmental Insurance What is environmental insurance and what does it insure against? Environmental insurance insures against potential damages

More information

Frequently Asked Questions about Hazardous Waste Lamps (e.g., fluorescent or other lights containing mercury)

Frequently Asked Questions about Hazardous Waste Lamps (e.g., fluorescent or other lights containing mercury) Frequently Asked Questions about Hazardous Waste Lamps (e.g., fluorescent or other lights containing mercury) I. Current Regulatory Status of Fluorescent Lamps in NC What is the current regulatory status

More information

Social Guidelines: Leasing Machinery and Equipment

Social Guidelines: Leasing Machinery and Equipment PROCESS DESCRIPTION Environmental product standards Companies in this sector may be leasing a wide range of machinery and equipment. Some of the more commonly leased items include: industrial equipment

More information

EPA s proposed hazardous waste pharmaceutical regulations

EPA s proposed hazardous waste pharmaceutical regulations EPA s proposed hazardous waste pharmaceutical regulations November 4, 2015 By J. Timothy Ramsey The United States Environmental Protection Agency ( EPA ) published proposed regulations in the Federal Register

More information

SECTION A - 2 HAZARDOUS MATERIALS REGULATIONS

SECTION A - 2 HAZARDOUS MATERIALS REGULATIONS SECTION A - 2 HAZARDOUS MATERIALS REGULATIONS A. Overview of Federal Hazardous Materials Legislation There are a number of Federal laws that regulate hazardous materials. The following is a brief overview

More information

ENVIRONMENTAL PROTECTION AGENCY

ENVIRONMENTAL PROTECTION AGENCY ENVIRONMENTAL PROTECTION AGENCY Fees Requires application fees for state isolated wetlands permits to be credited to the Surface Water Protection Fund, which is used for the administration of surface water

More information

What Constitutes Environmental Due Diligence?

What Constitutes Environmental Due Diligence? What Constitutes Environmental Due Diligence? Different Levels of Due Diligence for Different Types of Acquisitions: Green Fields, Brownfields, Operating Terminals and Leases By Gail A. Corrigan, Corrigan

More information

CERCLA Liability and Local Government Acquisitions and Other Activities

CERCLA Liability and Local Government Acquisitions and Other Activities United States Office of Enforcement and March 2011 Environmental Protection Agency Compliance Assurance EPA-330-F-11-003 Office of Site Remediation Enforcement CERCLA Liability and Local Government Acquisitions

More information

Assessment of Environmental Liability Insurance Options for Cleanup Activities

Assessment of Environmental Liability Insurance Options for Cleanup Activities Assessment of Environmental Liability Insurance Options for Cleanup Activities Brownfields Technology Support Center May 1999 ASSESSMENT OF ENVIRONMENTAL LIABILITY INSURANCE OPTIONS FOR CLEANUP ACTIVITIES

More information

TOXIC RELEASE INVENTORY Frequently Asked Questions

TOXIC RELEASE INVENTORY Frequently Asked Questions TOXIC RELEASE INVENTORY Frequently Asked Questions What is the Toxic Release Inventory? The Toxic Release Inventory or TRI, is a database that contains specific toxic chemical release, transfer, waste

More information

HAZARDOUS WASTE / MATERIALS GIS DATASETS and OTHER DATABASES

HAZARDOUS WASTE / MATERIALS GIS DATASETS and OTHER DATABASES HAZARDOUS WASTE / MATERIALS GIS DATASETS and OTHER DATABASES GIS DATASETS 1.1 CONTAMINATED SITES General Description: This folder is perhaps the most important because it pertains to sites where the surface

More information

BFPPs. Cleaning Up Their Own Property. William Keener Assistant Regional Counsel Office of Regional Counsel U.S. EPA Region 9

BFPPs. Cleaning Up Their Own Property. William Keener Assistant Regional Counsel Office of Regional Counsel U.S. EPA Region 9 BFPPs Cleaning Up Their Own Property William Keener Assistant Regional Counsel Office of Regional Counsel U.S. EPA Region 9 keener.bill@epa.gov (415) 972-3940 Bona Fide Prospective Purchasers Developers

More information

The Comprehensive Environmental Response,

The Comprehensive Environmental Response, Purpose and Applicability of Regulations The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) was enacted by Congress in 1980 to clean up the nation s hazardous waste sites

More information

Chapter 9.58 LOST, STOLEN, OR ABANDONED SHOPPING CARTS

Chapter 9.58 LOST, STOLEN, OR ABANDONED SHOPPING CARTS Chapter 9.58 LOST, STOLEN, OR ABANDONED SHOPPING CARTS Sections: 9.58.010 Findings And Purpose. 9.58.020 Definitions. 9.58.030 Enforcement of Chapter. 9.58.040 Required Signs On Carts. 9.58.050 Prohibiting

More information

012-0840-001 / September 25, 1996 / Page i

012-0840-001 / September 25, 1996 / Page i DOCUMENT NUMBER 012-0840-001 DEPARTMENT OF ENVIRONMENTAL PROTECTION OFFICE OF POLICY AND COMMUNICATIONS TITLE: AUTHORITY: POLICY TO ENCOURAGE VOLUNTARY COMPLIANCE BY MEANS OF ENVIRONMENTAL COMPLIANCE AUDITS

More information

ENVIRONMENTAL LIABILITY COMMERCIAL TRANSACTIONS

ENVIRONMENTAL LIABILITY COMMERCIAL TRANSACTIONS Daily Environment Report NUMBER 241 B-1 DECEMBER 17, 2012 ENVIRONMENTAL LIABILITY COMMERCIAL TRANSACTIONS This article focuses on contractual provisions for allocating environmental risks and liabilities

More information

U.S. Court of Appeals: Petroleum Wastewaters Treated To Remove Valuable Oil Are Not Solid Wastes

U.S. Court of Appeals: Petroleum Wastewaters Treated To Remove Valuable Oil Are Not Solid Wastes U.S. Court of Appeals: Petroleum Wastewaters Treated To Remove Valuable Oil Are Not Solid Wastes The U.S. Court of Appeals for the District of Columbia Circuit has held that the United States Environmental

More information

(1) Increase Collection of UEPs from Households

(1) Increase Collection of UEPs from Households US Senate Committee on Homeland Security and Governmental Affairs Recycling Electronics: A Common Sense Solution for Enhancing Government Efficiency and Protecting Our Environment Wednesday, February 27,

More information

The County Perspective. Electronic Waste (E-Waste)

The County Perspective. Electronic Waste (E-Waste) The County Perspective Electronic Waste (E-Waste) Testimony submitted by the New York State Association of Counties To the Assembly Standing Committee on Environmental Conservation, Commission On Solid

More information

EPA and HUD Real Estate Notification and Disclosure Rule Questions and Answers The Rule

EPA and HUD Real Estate Notification and Disclosure Rule Questions and Answers The Rule EPA and HUD Real Estate Notification and Disclosure Rule Questions and Answers The Rule What is the purpose of this rule and who is affected? To protect the public from exposure to lead from paint, dust,

More information

Update on Electronics Product Management April 8, 2003

Update on Electronics Product Management April 8, 2003 Update on Electronics Product Management This paper provides a brief overview of electronics management in Europe and the United States. Due to the passage of legislation in Europe, demand has accelerated

More information

Where and how to find environmental information about a property in Alberta

Where and how to find environmental information about a property in Alberta Buyer Beware Where and how to find environmental information about a property in Alberta do your due diligence Water Contamination Flood Carwash Oil & Gas Noise Purchasing real estate Do your due diligence

More information

Environmental Initiatives in Supply Chain Institute for Supply Management Southeast Michigan Meeting April 10, 2014

Environmental Initiatives in Supply Chain Institute for Supply Management Southeast Michigan Meeting April 10, 2014 Environmental Initiatives in Supply Chain Institute for Supply Management Southeast Michigan Meeting April 10, 2014 SAFE HARBOR LANGUAGE AND LEGAL DISCLOSURE This presentation contains certain statements

More information

Heather L. Hughes, J.D. HIPAA Privacy Officer U.S. Legal Support, Inc. hhughes@uslegalsupport.com www.uslegalsupport.com

Heather L. Hughes, J.D. HIPAA Privacy Officer U.S. Legal Support, Inc. hhughes@uslegalsupport.com www.uslegalsupport.com Heather L. Hughes, J.D. HIPAA Privacy Officer U.S. Legal Support, Inc. hhughes@uslegalsupport.com www.uslegalsupport.com HIPAA Privacy Rule Sets standards for confidentiality and privacy of individually

More information

This report has been prepared in accordance with Section 20.1 of the Illinois Environmental Protection Act.

This report has been prepared in accordance with Section 20.1 of the Illinois Environmental Protection Act. Hazardous Waste Generation and Management 1987-213 This report has been prepared in accordance with Section 2.1 of the Illinois Environmental Protection Act. Illinois Environmental Protection Agency Bureau

More information

HAZARDOUS WASTE MANAGEMENT PROGRAM

HAZARDOUS WASTE MANAGEMENT PROGRAM HAZARDOUS WASTE MANAGEMENT PROGRAM UNIVERSITY RISK MANAGEMENT Occupational Safety and Health Programs 19 Hagood Avenue, Suite 908 Charleston, SC 29425 843-792-3604 Revised: January 2015 TABLE OF CONTENTS

More information

Cathode Ray Tubes. Case Studies Chris Cahnovsky, IEPA

Cathode Ray Tubes. Case Studies Chris Cahnovsky, IEPA Cathode Ray Tubes Case Studies Chris Cahnovsky, IEPA CRTs in Open Dumps Definitions Why CRT are hazardous Two CRT scrapping case studies One CED Collector case study CRTs in an open dump Cathode Ray Tube

More information

MANUAL O R I E N T A T I O N. United States Environmental Protection Agency. Resource Conservation and Recovery Act

MANUAL O R I E N T A T I O N. United States Environmental Protection Agency. Resource Conservation and Recovery Act O R I E N T A T I O N MANUAL United States Environmental Protection Agency Resource Conservation and Recovery Act RCRA Orientation Manual January 2003 EPA530-R-02-016 TABLE OF CONTENTS Use of the Manual...

More information

Anderson Brothers, Inc. v. St. Paul Fire and Marine Insurance Co.

Anderson Brothers, Inc. v. St. Paul Fire and Marine Insurance Co. Public Land and Resources Law Review Volume 0 Fall 2013 Case Summaries Anderson Brothers, Inc. v. St. Paul Fire and Marine Insurance Co. Katelyn J. Hepburn University of Montana School of Law, katelyn.hepburn@umontana.edu

More information

UNDERGROUND OIL STORAGE TANKS

UNDERGROUND OIL STORAGE TANKS L E S P E R A N C E M E N D E S L A W Y E R S UNDERGROUND OIL STORAGE TANKS A Property Owner s Guide Robert J Lesperance and Naomi R Rozenberg If your home, townhouse or condominium was built before 1970,

More information

Accountability Report Card Summary 2013 Tennessee

Accountability Report Card Summary 2013 Tennessee Accountability Report Card Summary 2013 Tennessee Tennessee has one of the strongest state whistleblower laws: Scoring 75 out of a possible 100; Ranking 3 rd out of 51 (50 states and the District of Columbia).

More information

Sample Due Diligence Checklist

Sample Due Diligence Checklist Sample Due Diligence Checklist 01.0. CORPORATE ORGANIZATION AND HISTORY 1.1. - Overview of corporate legal structure, banking relationships (other than transaction financing), organizational charts and

More information

Accountability Report Card Summary 2013 Pennsylvania

Accountability Report Card Summary 2013 Pennsylvania Accountability Report Card Summary 2013 Pennsylvania Pennsylvania has a passable state whistleblower law: Scoring 61 out of a possible 100; Ranking 17 th out of 51 (50 states and the District of Columbia).

More information

Massachusetts Brownfields Program: An Overview

Massachusetts Brownfields Program: An Overview Massachusetts Brownfields Program: An Overview Across Massachusetts, contamination from decades of industrial activity had left many old factories and other sites abandoned or underused, posing risks to

More information

(1) regulate the storage, retention, transmission, and security measures for credit card, debit card, and other payment-related data;

(1) regulate the storage, retention, transmission, and security measures for credit card, debit card, and other payment-related data; Legal Updates & News Legal Updates Pending Changes to California s Data Breach Law: New Burdens for Retailers? September 2007 by Christine E. Lyon, William L. Stern Related Practices: Privacy and Data

More information

Tax Deeding. What Choices do we have?

Tax Deeding. What Choices do we have? Tax Deeding What Choices do we have? Information for this presentation gathered from Town & City Magazine by NH LGC. Tax Deeded Property (Oct 2010) and Tax Deeded Property: After the Collector s Deed is

More information

RCRA ENFORCEMENT AND COMPLIANCE

RCRA ENFORCEMENT AND COMPLIANCE RCRA ENFORCEMENT AND COMPLIANCE CONTENTS 1. Introduction... 1 2. Statutory Summary... 2 2.1 Enforcement Authorities... 2 2.2 Inspections and Information Gathering... 2 2.3 Monitoring, Analysis, Testing,

More information

Incorporating Greener Cleanups into Remedy Reviews

Incorporating Greener Cleanups into Remedy Reviews Association of State and Territorial Solid Waste Management Officials (ASTSWMO) Incorporating Greener Cleanups into Remedy Reviews Prepared by the Greener Cleanups Task Force Under the Sustainability Subcommittee

More information

FEES GUIDE TO OUR FEES UNDERSTANDING YOU, FIRST...

FEES GUIDE TO OUR FEES UNDERSTANDING YOU, FIRST... FEES * GUIDE TO OUR FEES As a firm, we wish to be open and transparent about our costs and the options for payment. When a transaction becomes more involved due to additional requirements or complexity,

More information

HIPAA The Law Explained. Click here to view the HIPAA information.

HIPAA The Law Explained. Click here to view the HIPAA information. HIPAA The Law Explained Click here to view the HIPAA information. HIPAA - Provisions 5 Major Provisions/Titles Title 1 Title 2 Title 3 Title 4 Title 5 More Information on Administrative Simplification

More information

MOTOR VEHICLE DEALER SALESPERSON STUDY GUIDE MATERIALS

MOTOR VEHICLE DEALER SALESPERSON STUDY GUIDE MATERIALS MOTOR VEHICLE DEALER SALESPERSON STUDY GUIDE MATERIALS 2201 West Broad Street, Suite 104 Richmond, Virginia 23220 804-367-1100 www.mvdb.virginia.gov MVDB 35 REVISED 07/01/15 INTRODUCTION This study guide

More information

The Comprehensive Environmental Response,

The Comprehensive Environmental Response, Purpose and Applicability of Regulations Chapter 7 The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) was enacted by Congress in 1980 to clean up the nation s hazardous

More information

This is Superfund. A Community Guide to EPA s Superfund Program

This is Superfund. A Community Guide to EPA s Superfund Program This is Superfund A Community Guide to EPA s Superfund Program IF THERE IS A SUPERFUND SITE in your neighborhood, you are probably wondering, what will happen? and, what can I do? This brochure will give

More information

Best Practices for Responsible Disposal of Tape Media

Best Practices for Responsible Disposal of Tape Media Best Practices for Responsible Disposal of Tape Media The Environmental and Economic Benefits of Recycling vs. Destruction White Paper The Data Media Source San Jose, CA Data Media Source 2006 For use

More information

Disclosure Requirements Concerning Lead-Based Paint in Housing: Questions and Answers

Disclosure Requirements Concerning Lead-Based Paint in Housing: Questions and Answers Disclosure Requirements Concerning Lead-Based Paint in Housing: Questions and Answers By Legislative Affairs Updated June, 2003 Institute of Real Estate Management 430 N. Michigan Avenue Chicago, IL 60611

More information

Universal Waste Management

Universal Waste Management Universal Waste Management Reference 22CCR 66273.1 et seq., Universal Waste Rules CSUCI is a Small Quantity Handler of Universal Waste Universal Wastes Are... Small Batteries; including nickel cadmium,

More information

LeadPaint-EPA regulations Effective 4/22/10. CONTRACTORS Renovating, Repair & Painting

LeadPaint-EPA regulations Effective 4/22/10. CONTRACTORS Renovating, Repair & Painting LeadPaint-EPA regulations Effective 4/22/10 CONTRACTORS Renovating, Repair & Painting The EPA has introduced new Lead Paint regulations imposing numerous obligations on contractors that are performing

More information

SEMGROUP CORPORATION. Anti-Corruption Compliance Policy August, 2011

SEMGROUP CORPORATION. Anti-Corruption Compliance Policy August, 2011 SEMGROUP CORPORATION Anti-Corruption Compliance Policy August, 2011 SCOPE This is a global policy (the Policy ) applicable to the worldwide operations of SemGroup Corporation ("SemGroup") and all of its

More information

Colocation Master Services Vol.1.0

Colocation Master Services Vol.1.0 Colocation Master Services Vol.1.0 THIS COLOCATION MASTER SERVICE AGREEMENT ( Colo MSA or Colocation MSA ) shall apply to Service Orders or Agreements ( agreement(s), service order(s), or contract(s) )

More information

How Corporations Evade Liability for Pollution at Closed Mines

How Corporations Evade Liability for Pollution at Closed Mines A Mining Truth Report How Corporations Evade Liability for Pollution at Closed Mines Conservation Minnesota Friends of the Boundary Waters Wilderness Minnesota Center for Environmental Advocacy www.miningtruth.org

More information

I. BASICS OF COLORADO LANDLORD/TENANT LAW A. Statutes: Colorado Security Deposit Act: Colo. Rev. Stat. 1973 38-12-101 to 103 (1982 & Supp. 1990).

I. BASICS OF COLORADO LANDLORD/TENANT LAW A. Statutes: Colorado Security Deposit Act: Colo. Rev. Stat. 1973 38-12-101 to 103 (1982 & Supp. 1990). I. BASICS OF COLORADO LANDLORD/TENANT LAW A. Statutes: Colorado Security Deposit Act: Colo. Rev. Stat. 1973 38-12-101 to 103 (1982 & Supp. 1990). Colorado Mobile Home Park Act: Colo. Rev. Stat. 38-12-200.1

More information

ENVIRONMENTAL ENFORCEMENT: WHAT THE OWNER REALLY NEEDS TO KNOW

ENVIRONMENTAL ENFORCEMENT: WHAT THE OWNER REALLY NEEDS TO KNOW Page 1 of 5 ENVIRONMENTAL ENFORCEMENT: WHAT THE OWNER REALLY NEEDS TO KNOW The Metropolitan Corporate Counsel, August 2000, p. 21, authored by John E. Osborn, Esq. Our law firm s practice concentrates

More information

3/13/2015 HIPAA/HITECH WHAT S YOUR COMPLIANCE STATUS? Daniel B. Mills Pretzel & Stouffer, Chartered WHAT IS HIPAA?

3/13/2015 HIPAA/HITECH WHAT S YOUR COMPLIANCE STATUS? Daniel B. Mills Pretzel & Stouffer, Chartered WHAT IS HIPAA? HIPAA/HITECH WHAT S YOUR COMPLIANCE STATUS? Daniel B. Mills Pretzel & Stouffer, Chartered WHAT IS HIPAA? 1 DEFINITIONS HIPAA Health Insurance Portability and Accountability Act of 1996 Primarily designed

More information

federal register Environmental Protection Agency Part II Thursday October 22, 1998

federal register Environmental Protection Agency Part II Thursday October 22, 1998 federal register Thursday October 22, 1998 Part II Environmental Protection Agency 40 CFR Parts 264, 265, 270, and 271 Standards Applicable to Owners and Operators of Closed and Closing Hazardous Waste

More information

Source: http://www.uscg.mil/hq/g-m/pscweb/boarding%20matrix.htm.

Source: http://www.uscg.mil/hq/g-m/pscweb/boarding%20matrix.htm. FAQs for Detainees in Marine Pollution Prosecutions Under what authority may the Coast Guard board a vessel? Under the United Nations Convention on the Law of the Sea, a coastal state has full and exclusive

More information

Environmental Issues & Public Affairs

Environmental Issues & Public Affairs Your knowledge of basic environmental laws and your role as PAO in supporting your command's efforts is critical to your ability to support your command's public information efforts. If you have ever worked

More information

A Guide for Used Oil Transporter Training Programs. Following are excerpts from laws and rules pertaining to Used Oil Transporter Certification

A Guide for Used Oil Transporter Training Programs. Following are excerpts from laws and rules pertaining to Used Oil Transporter Certification A Guide for Used Oil Transporter Training Programs Introduction An used oil transporter that transports over public highways more than 500 gallons of used oil annually, not including oily waste, must become

More information

Compliance Plan False Claims Act & Whistleblower Provisions Purpose/Policy/Procedures

Compliance Plan False Claims Act & Whistleblower Provisions Purpose/Policy/Procedures CATHOLIC CHARITIES OF THE ROMAN CATHOLIC DIOCESE OF SYRACUSE, NY and TOOMEY RESIDENTIAL AND COMMUNITY SERVICES Compliance Plan False Claims Act & Whistleblower Provisions Purpose/Policy/Procedures Purpose:

More information

Village of Hastings-on-Hudson Electronic Policy. Internal and External Email Policies and Procedures

Village of Hastings-on-Hudson Electronic Policy. Internal and External Email Policies and Procedures Village of Hastings-on-Hudson Electronic Policy Internal and External Email Policies and Procedures Effective February 2012 1 1. Table of Contents 1. General Policies... 3 1.1 Establishment and upkeep

More information

CALIFORNIA FAIR DEBT COLLECTION PRACTICES ACT Updated 1 January 2012

CALIFORNIA FAIR DEBT COLLECTION PRACTICES ACT Updated 1 January 2012 I. BACKGROUND CALIFORNIA FAIR DEBT COLLECTION PRACTICES ACT Updated 1 January 2012 A. Contents: This memorandum summarizes California's Fair Debt Collection Practices Act, California Civil Code (the "CCC")

More information

PENALTIES AND OTHER REMEDIES FOR ENVIRONMENTAL VIOLATIONS: AN OVERVIEW

PENALTIES AND OTHER REMEDIES FOR ENVIRONMENTAL VIOLATIONS: AN OVERVIEW INECE SECRETARIAT STAFF 299 PENALTIES AND OTHER REMEDIES FOR ENVIRONMENTAL VIOLATIONS: AN OVERVIEW INECE SECRETARIAT STAFF 2141 Wisconsin Ave. NW, Suite D2 Washington, DC 20007, inece@inece.org SUMMARY

More information

SEC Partner Teleconference September 29, 2010

SEC Partner Teleconference September 29, 2010 SEC Partner Teleconference September 29, 2010 What is the Problem? Computer hardware is expected to last 7 years Equipment purchased by institutional and commercial buyers is used for an average of 3 years

More information

EPA s Proposed Rule Regulating Pharmaceuticals Under RCRA

EPA s Proposed Rule Regulating Pharmaceuticals Under RCRA EPA s Proposed Rule Regulating Pharmaceuticals Under RCRA September 3, 2015 Environmental EPA proposed a rule to regulate hazardous waste pharmaceuticals which include a number of FDA-approved drugs under

More information

Business Information Series 2012 Vol. I No.3 SIGNING A COMMERCIAL LEASE. Dubai Business Guide. Markets

Business Information Series 2012 Vol. I No.3 SIGNING A COMMERCIAL LEASE. Dubai Business Guide. Markets Business Information Series 2012 Vol. I No.3 SIGNING A COMMERCIAL LEASE Dubai Business Guide Markets Business Support Department Dubai Chamber of Commerce and Industry Published by: Dubai Chamber of Commerce

More information

EPA Region 3/ Pa Dept of Environmental Protection Streamlining the Process for the One Cleanup Program Under RCRA

EPA Region 3/ Pa Dept of Environmental Protection Streamlining the Process for the One Cleanup Program Under RCRA EPA Region 3/ Pa Dept of Environmental Protection Streamlining the Process for the One Cleanup Program Under RCRA September 2005 On April 21, 2004, Pennsylvania Environmental Protection Secretary Kathleen

More information

Prepared by: The Office of Corporate Compliance & HIPAA Administration

Prepared by: The Office of Corporate Compliance & HIPAA Administration Gwinnett Health System s Annual Education 2014 Corporate Compliance: Our Commitment to Excellence Prepared by: The Office of Corporate Compliance & HIPAA Administration Objectives After completing this

More information

Louisiana Department of Health and Hospitals Basic HIPAA Privacy Training: Policies and Procedures

Louisiana Department of Health and Hospitals Basic HIPAA Privacy Training: Policies and Procedures Louisiana Department of Health and Hospitals Basic HIPAA Privacy Training: Policies and Procedures 1 What Is HIPAA? HIPAA (pronounced hippa) is a federal law. It s a set of rules and regulations that affect

More information

GAO ELECTRONIC WASTE. Considerations for Promoting Environmentally Sound Reuse and Recycling

GAO ELECTRONIC WASTE. Considerations for Promoting Environmentally Sound Reuse and Recycling GAO July 2010 United States Government Accountability Office Report to the Chairman, Committee on Science and Technology, House of Representatives ELECTRONIC WASTE Considerations for Promoting Environmentally

More information

EVICTIONS. in Baltimore City. PROCEDURES for tenants and landlords

EVICTIONS. in Baltimore City. PROCEDURES for tenants and landlords EVICTIONS in Baltimore City PROCEDURES for tenants and landlords Evictions in Baltimore City Procedures for tenants and landlords Landlord Scheduling and Notifying Tenant of the Date of Eviction, What

More information

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460. June 19 1987

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460. June 19 1987 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 June 19 1987 MEMORANDUM SUBJECT: Interim Guidance on Settlements with De Minimis Waste Contributors under Section 122(g) of SARA FROM:

More information

Responsibly Retiring IT Assets, Medical or Laboratory Equipment

Responsibly Retiring IT Assets, Medical or Laboratory Equipment Responsibly Retiring IT Assets, Medical or Laboratory Equipment Agenda Introductions David Zimet, President, Hesstech, LLC Industry Overview Key Issues When Retiring Electronic Equipment Data Security

More information

Environmental & Social Risk Management in Banks

Environmental & Social Risk Management in Banks UNEP Finance Initiative Environmental & Social Risk Management in Banks Mark Thompson, Director Legal Legal Direct Impacts of Environmental Issues on Businesses Benefit Benefit Financial Financial Cost

More information

What Foreign Investors need to know when Buying, Selling or Leasing Real Estate in Florida

What Foreign Investors need to know when Buying, Selling or Leasing Real Estate in Florida What Foreign Investors need to know when Buying, Selling or Leasing Real Estate in Florida By: Kevin F. Jursinski Florida Board Certified Real Estate, Business Litigation and Construction Litigation Attorney

More information

HERITAGE FARM POLICY AND PROCEDURES. Policy: False Claims Act and Whistleblower Provisions

HERITAGE FARM POLICY AND PROCEDURES. Policy: False Claims Act and Whistleblower Provisions HERITAGE FARM POLICY AND PROCEDURES Policy: False Claims Act and Whistleblower Provisions Date: October 8, 2013 Rationale: It is Heritage Farm s intent to make sure all claims are submitted in a timely

More information