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EPA and DOJ Reach $9.5 Million settlement with Stericycle for RCRA Violations

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On January 16, 2025, the U.S. Environmental Protection Agency (EPA) and the Department of Justice (DOJ) announced a $9.5 million settlement with Stericycle, Inc. for violations of the Resource Conservation and Recovery Act (RCRA) and related regulations. This is the first judicial action enforcing the EPA’s e-Manifest requirements.


Between May 5, 2014, and April 6, 2020, Stericycle failed to properly manage hazardous waste, maintain accurate manifest records during transportation, and submit timely information for thousands of manifests to the EPA’s electronic manifest database, known as the e-Manifest system. These lapses occurred while Stericycle operated 13 RCRA-permitted hazardous waste treatment, storage, and disposal facilities, along with 44 waste transfer facilities nationwide.


Acting Assistant Administrator Cecil Rodrigues of the EPAs Office of Enforcement and Compliance Assurance emphasized the gravity of these violations, stating, “Stericycle repeatedly failed to ensure the proper transport, management, and storage of hazardous waste—a job that they were paid to do and entrusted to perform on behalf of customers nationwide.”


Stericycle sold the majority of its hazardous waste operations to Harsco Corporation on April 6, 2020, and has largely ceased managing hazardous waste in the United States since. Despite the sale, Stericycle remains accountable for the violations between 2014 and 2020. The proposed settlement is pending approval by the U.S. District Court for the Southern District of New York.


While the impacts on Treatment, Storage, and Disposal Facilities (TSDFs) are clear, hazardous waste generators must remain vigilant in overseeing their waste vendors. This is crucial to fulfill their Resource Conservation and Recovery Act (RCRA) “cradle-to-grave” responsibilities. Generators should prioritize the following:

  • Manifest Tracking: Diligently track manifests to ensure they are completed and returned, confirming proper waste disposal.

  • Regular TSDF Audits: Conduct periodic audits of their TSDFs to verify that waste is being managed in compliance with all regulations and that accurate recordkeeping is maintained.



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