Stericycle, Inc.
Outcome
Stericycle agreed to pay a $9.5 million civil penalty — one of the largest ever assessed for RCRA violations — resolving systematic nationwide violations between 2014 and 2020 including routinely losing track of hazardous waste during transport, sending waste to non-customer-selected disposal facilities, and delivering shipments without required manifests.
Details
Stericycle, Inc. — Nationwide RCRA Hazardous Waste Tracking Violations (2025)
Outcome: Stericycle, Inc. agreed to pay a $9.5 million civil penalty — one of the largest civil penalties ever assessed for RCRA violations — resolving systematic, nationwide violations between May 2014 and April 2020 including routinely losing track of hazardous waste during transport, sending hazardous waste to disposal facilities not selected by customers, and delivering waste shipments without required RCRA manifests.
Stericycle, Inc., headquartered in Bannockburn, Illinois, operated a nationwide hazardous waste management business providing hazardous waste collection, transportation, and disposal services to businesses, healthcare facilities, and government entities across the United States. Between May 5, 2014, and April 6, 2020, Stericycle's operations systematically violated RCRA requirements governing the tracking and transportation of hazardous waste.
The violations were not isolated incidents but represented routine operational failures: Stericycle regularly lost track of hazardous waste while it was in transit — a fundamental failure of the RCRA manifest tracking system designed to ensure cradle-to-grave accountability for hazardous waste. The company also sent hazardous waste to disposal facilities that had not been selected or approved by its customers — the generators of the waste who bear ultimate responsibility under RCRA for ensuring their waste is properly managed — and delivered waste shipments to treatment, storage, and disposal facilities without the required RCRA manifest documents that create the legal chain of custody.
The settlement, announced January 16, 2025, required Stericycle to pay the $9.5 million civil penalty. The case was notable as one of the largest civil penalty assessments in RCRA enforcement history, reflecting EPA's determination that systematic, nationwide tracking failures by a major hazardous waste management company warranted an enforcement response proportionate to the scale of the violations and the company's role as a trusted custodian of third-party hazardous waste.
Primary Source: Stericycle, Inc. RCRA Settlement Summary | US EPA
How Crucible Prevents This
Stericycle's violations — routinely losing track of hazardous waste, routing it to unauthorized destinations, and missing manifest documentation — represent exactly the type of systematic process failure that Crucible's session-memory architecture prevents. A decision log capturing every hazardous waste pickup, transport, and disposal chain of custody, combined with a compliance calendar tracking manifest submission requirements, would prevent the chain-of-custody gaps that drove six years of violations. The $9.5 million penalty reflects the scale of systematic noncompliance rather than isolated incidents.
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