Philern Corp.
Case Number: SLS No. 98-006
Title: Philern Corp., Part 1
Case Files: Case (17 pages) | Exhibits (14 pages)
Teaching Note:
Author: Mary J. Decker, Case Writer; Barton H. (“Buzz”) Thompson, Jr., Robert E. Paradise Professor of Natural Resources Law
Abstract: The owners of a biotech company face a possible hazardous waste enforcement action by the State environmental agency, after a series of inspections reveal noncompliance with various RCRA requirements. The biotech company believes RCRA regulatory requirements designed with large industrial waste generators in mind are unnecessary and unreasonable for a biotech research laboratory to comply with. The company must decide how to address these RCRA compliance and operational issues when it meets face-to-face with State regulators in an effort to resolve the alleged RCRA violations.
Key Words: Resource Conservation and Recovery Act; RCRA; laboratory hazardous waste, satellite accumulation areas, central waste accumulation areas, off-site storage, rogue employees, governmental inspections, environmental health and safety; governmental relations.
Case Number: SLS No. 98-008
Title: Philern Corp., Part 2
Case Files: Case (2 pages) | Exhibits (47 pages)
Teaching Note:
Author: Mary J. Decker, Case Writer; Barton H. (“Buzz”) Thompson, Jr., Robert E. Paradise Professor of Natural Resources Law
Abstract: This 2 page addendum to the Philern Corp. Part 1 case study describes the efforts of the Laboratory Regulatory Reform Task Force in California to improve existing hazardous waste regulations applicable to laboratories. The Exhibits include the Task Force recommendations forwarded to the State environmental agency and the State agency’s resulting interim final policy on the key regulatory issues identified by the Task Force.
Key Words: Resource Conservation and Recovery Act; RCRA; laboratory hazardous waste, regulatory reform.