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EPA’s Warehouse and Consumer Products Enforcement Initiative

Product distribution, logistics, transportation, wholesale, big box retail, food service and refrigeration, pharmaceutical, and related warehousing operations are usually not thought of as EPA enforcement targets, but that has changed. Environmental regulators have increased their focus on these businesses because they handle household and consumer chemical products, particularly returned, damaged, off-spec, and obsolete products.

A variety of household and consumer chemical products, such as kitchen and bathroom cleaners, pesticides, aerosol disinfectants and the like may actually be regulated “hazardous wastes” after a decision is made to discard them. And although these products seem relatively benign – in the sense that we encounter them in our daily lives and they are routinely used in our homes and businesses – a number of companies have faced significant civil, and in some cases criminal, penalties for improper management and disposal of such products.

In addition to product management, warehouses and retail stores may have other environmental, safety, and health issues that are easy to overlook: refrigerant and cooling system leaks, used oil/fluids and batteries from forklifts, spent fluorescent bulbs, and stormwater and wastewater discharges to sanitary sewers.

Combine this mix of factors with the fact that companies frequently rely upon offsite locations, contractors, third-party vendors, and temporary staff to manage these operations – where the lines of responsibility and authority may not always be clear – and this creates a scenario ripe for EPA enforcement.

In this webinar recording, Spencer Fane Britt & Browne LLP environmental lawyers, leading authorities on these issues, will help you:

  • identify the current developments and trends regarding the environmental focus on warehousing, distribution, and retail operations;
    learn about national and regional enforcement cases;
  • recognize the dynamics that may present challenges to compliance such as the use of contractors and third-party vendors; and
  • understand the various regulatory drivers and environmental compliance issues, including the management of everyday household and consumer chemical products that may become hazardous wastes when discarded.

Click here to access the recording.

Click here to download presentation slides.