Enforcement in New England
Resource Conservation and Recovery Act (RCRA) Regulatory Interpretations
Regional EPA Guidance (Pfizer Inc.)
On March 16, 1999, a Consent Decree was entered in Federal District Court, District of Connecticut, resolving a Complaint filed against Pfizer Inc., located in Groton, Connecticut. The Complaint alleged violations of the Resource Conservation and Recovery Act (RCRA), the Clean Water Act and the Emergency Planning and Community Right-to-Know Act. In conjunction with the settlement, Region I issued to Pfizer regulatory interpretations of certain RCRA requirements in order to facilitate future compliance at Pfizer's Groton facility. The specific requirements for which regulatory interpretations were issued are: satellite accumulation, movement of hazardous wastes to storage areas; stacking and configuration of drums to allow for proper inspection; inspection logs; and container labeling in laboratories. Some of the interpretations, such as those for the inspection log and container labeling requirements, are based on federally-authorized Connecticut hazardous waste regulations which are more stringent than the federal requirements. Moreover, the satellite accumulation interpretation has been geared toward specific factual scenarios that existed at the Pfizer plant in Groton, Connecticut. Nevertheless, the interpretations may prove useful to the regulated community in general throughout New England. The interpretations are set forth on the left. If you have any questions regarding these interpretations, please contact Richard Piligian at (617) 918-1757, or Andrea Simpson at (617) 918-1738.