The evidence shows that fines and penalties for hazardous waste violations in the U.S. have increased in 2025, especially driven by two key factors:
✅ What the data show
- The US Environmental Protection Agency (EPA) raised the maximum civil penalty under the Resource Conservation and Recovery Act (RCRA) hazardous waste program from $90,702 to $93,058 effective January 8, 2025. (lion.com)
- The EPA announced a major penalty settlement of $9.5 million (with the Department of Justice) for violations of hazardous waste manifest requirements by Stericycle, Inc.. (US EPA)
- Enforcement round-up data show that while overall settlement numbers (“actions”) may have decreased in Q1 2025 (196 agreements vs 215 in Q4 2024) the fines are at relatively high levels. (ehsdailyadvisor.com)
🔍 What this means for “large hazardous waste generators”
- Although the data are not explicitly broken out by “large quantity generators” (LQGs) alone, the above RCRA program covers hazardous waste generators, transporters, and treatment/storage/disposal facilities.
- The increase in the maximum penalty means larger potential exposure for violations by LQGs.
- The large $9.5 million settlement signals that the EPA is willing to seek substantial penalties for serious violations in the hazardous waste generator/management sector.
- For example, in addition to the manifest case, there is mention of a gold-mining facility in Alaska facing a $275,000 penalty in 2025 for hazardous waste violations including LQG requirements. (lion.com)
⚠️ Important caveats
- Increase in maximum possible penalties ≠ guaranteed increase in average fines or number of fines.
- The data for 2025 are still early (first quarter, etc.), so full-year trends are not yet available.
- The published summaries (e.g., EPA enforcement round-ups) often cover all environmental programs (air, water, waste) rather than isolating hazardous waste generator violations alone.
🧮 Conclusion
Large hazardous waste generators can expect higher penalty risk in 2025 (both via higher statutory maximums and evidenced large settlements). Whether the average fine amount for LQGs has increased remains less clearly documented publicly at this point, but the indicators point in that direction.
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