Stericycle, Inc. RCRA Settlement Summary

On January 17, 2025, the Environmental Protection Agency (EPA) and the Department of Justice announced a settlement agreement with Stericycle, Inc., a national provider of hazardous waste transportation, storage, and disposal services, for violations of the Resource Conservation and Recovery Act’s (RCRA) regulations regarding hazardous waste transport, storage, and recordkeeping.  

Under the settlement agreement Stericycle will pay a $9.5 million civil penalty, one of the largest civil penalties ever paid for RCRA violations. 

This settlement resolves Stericycle’s failures to properly manage hazardous waste, accurately maintain required manifest records when transporting hazardous waste, and timely submit information for thousands of manifests to EPA’s electronic manifest database, the e-Manifest system.  

The e-Manifest system facilitates the electronic transmission of the uniform hazardous waste manifest form, which accompanies shipments of hazardous waste. Information on the system is available on the Agency’s The Hazardous Waste Electronic Manifest (e-Manifest) System website. 

On this page:

• Overview of Stericycle, Inc.
• Summary of the Violations
• Overview of  Settlement Agreement
• Contact Information

Overview of Stericycle, Inc.

Stericycle, headquartered in Bannockburn, IL, is a publicly traded waste management company that operated a nationwide hazardous waste transportation, storage, treatment, and disposal business until it sold most of the business on April 6, 2020. Stericycle operated 13 RCRA-permitted hazardous waste treatment, storage, and disposal facilities (TSDFs) and 44 hazardous waste transfer facilities. On April 6, 2020, Stericycle completed the sale of its “Stericycle Environmental Solutions” hazardous waste business and, since that date, has largely ceased managing hazardous waste in the United States. However, Stericycle remained accountable for its systemic RCRA violations prior to that sale.  

Stericycle conducted its hazardous waste business in all ten EPA regions and numerous states. Its customers (generators of hazardous waste) included federal facilities and state government entities, as well as small and large private sector companies.  

Summary of the Violations

Between May 5, 2014, and the April 6, 2020, which is the date Stericycle sold its business, Stericycle routinely violated RCRA requirements related to tracking and transportation of hazardous waste. Stericycle regularly lost track of hazardous waste while transporting it, sent hazardous waste to disposal facilities that were not selected by its customers, and delivered hazardous waste shipments without the required manifests. Stericycle also failed to comply with requirements for resolving and reporting discrepancies between hazardous waste identified on a shipping manifest and the hazardous waste received by Stericycle at its facilities for disposal, and it failed to timely return signed manifests to generators and timely submit them electronically to EPA.  

Stericycle also violated RCRA by storing hazardous waste in transfer facilities, either because the storage period was longer than the 10 days or because overall transportation times for the hazardous waste shipment exceeded those constituting “the normal course of transportation” under RCRA regulations. All this conduct violated RCRA hazardous waste regulations critical to preventing substantial risks to human health and the environment.

 The complaint states that Stericycle:

1. While transporting shipments of hazardous wastes, Stericycle failed to deliver the entire quantity of hazardous waste to the designated facility on the shipment manifests numerous times. 40 C.F.R. § 263.21(a).  
2. Stericycle improperly directed hazardous wastes to an alternate facility other than the facility properly designated on the wastes’ manifests on multiple occasions. 40 C.F.R. § 263.21. 
3. Stericycle repeatedly stored hazardous waste at transfer facilities for more than 10 days and/or outside the normal course of transportation without a RCRA permit. 42 U.S.C. § 6925(a) and 40 C.F.R. § 270.1(b). 
4. Stericycle repeatedly failed to ensure that the required hazardous waste manifests accompanied the hazardous waste it accepted for transportation. 40 C.F.R. § 263.20(c).  
5. Stericycle on numerous occasions failed to properly resolve and report discrepancies between the hazardous waste identified on a manifest and the hazardous waste its facilities received for disposal. 40 C.F.R. § 264.72(c). 
6. Stericycle failed to return final signed copies of manifests for hazardous waste shipments it handled to its customers, the generators of that waste, in time for numerous manifests. 40 C.F.R. § 264.71(a)(2)(iv). 
7. Stericycle failed to timely submit its hazardous waste manifests to EPA’s electronic manifest reporting system for thousands of manifests (e-Manifest). 40 C.F.R. § 264.71(a)(2)(v). 

Overview of Settlement Agreement

Under the terms of the settlement Stericycle agrees to pay a civil penalty of $9.5 million, one of the largest civil penalties ever obtained under RCRA. Because Stericycle no longer owns or operates the facilities at issue, there are no conditions for bringing Stericycle into compliance and this settlement is not subject to a public comment period. 

Contact Information

For more information, please contact:

Lauren Stroyeck, Attorney-Advisor 
Waste and Chemical Enforcement Division  
Office of Civil Enforcement 
Office of Enforcement and Compliance Assurance  
[email protected]