Tulane’s Toxic Paperwork: How A Primate Lab Botched Federal Hazardous Waste Law And Walked Away With A $15,000 Slap

EvilCorporations.com • EPA Docket No. RCRA-06-2024-0948 • 12 min read

Tulane University runs one of the country’s federally licensed biomedical primate research centers. That means it regularly handles chemicals so dangerous the EPA puts them on a special short list of substances that demand the strictest tracking in the country. In 2019, Tulane’s facility got the paperwork catastrophically wrong. The EPA didn’t find out until a record review that started in 2023. The consequences for Tulane? A fine smaller than most Americans’ annual car insurance bill.

• The Tulane National Primate Research Center sits at 18703 Three Rivers Road in Covington, Louisiana. It is licensed by the USDA as a Class B animal dealer, meaning it can legally buy and sell animals for research. It is also registered with the EPA as a generator of hazardous waste.
• Federal law under RCRA, specifically Section 3002, requires every hazardous waste generator to accurately identify what they are disposing of. That identification has to appear on a manifest, a legally binding shipping document that tracks the waste from the moment it leaves the facility to the moment it is destroyed or treated.
• Tulane failed to make an accurate hazardous waste determination for its waste streams in 2019. The manifests filed that year listed two substances under P-list acute hazardous waste codes: sodium azide (P105) and potassium cyanide (P098). Both errors were discovered not by routine inspections or whistleblowers, but by a paper records review that EPA began nearly four years after the fact.

What Can’t Be Settled With A Check

There are no identified individual victims in this case. The EPA document does not name a single worker, community resident, or animal harmed by Tulane’s paperwork failures. That absence is itself a kind of story.

The communities surrounding Covington, Louisiana already live inside a landscape scarred by industrial contamination. Louisiana’s environmental justice record is among the worst in the country. The communities downriver from industrial facilities, many of them Black and low-income, have fought for decades to be taken seriously when they report strange smells, sick children, or water that runs the wrong color. The infrastructure of environmental law, the manifests, the waste codes, the generator registrations, exists precisely because ordinary people cannot see, smell, or identify potassium cyanide or sodium azide in a container. They have to trust the paperwork. Tulane got the paperwork wrong for years and nobody outside the university knew until the EPA quietly pulled the records.

The people who live near 18703 Three Rivers Road in Covington were never told. There was no public alert. There was no press release. There was a records review, a series of conversations between Tulane’s representatives and EPA officials, and then a settlement. The community’s role in this process was exactly nothing.

Consider also the workers inside the facility. The Tulane National Primate Research Center employs researchers, veterinary staff, and animal care technicians who work daily in the same rooms where chemicals like potassium cyanide are handled. Proper hazardous waste classification is not just a bureaucratic formality. It determines what protective protocols are in place, how emergency responders would react if something went wrong, and what disposal contractors expect to receive. When a facility mislabels its waste, the chain of safety that RCRA was designed to create develops invisible holes. Workers downstream, including transport drivers and treatment facility employees, rely on manifest accuracy to know what they are handling. They were not asked to sign any consent agreement.

And then there is the broader insult of the timeline. The violation occurred in 2019. The investigation began in 2023. The fine was assessed in April 2024. At no point during those five years was there any public process, any community meeting, any opportunity for the people of Covington or neighboring St. Tammany Parish to ask questions or demand answers. The legal system resolved this entirely among institutions, at a price point that communicates loudly to every other hazardous waste generator in EPA Region 6: the cost of getting it wrong is fifteen thousand dollars.

Verbatim: What The EPA Document Actually Says

These are the direct words from EPA Docket No. RCRA-06-2024-0948. Every quote below comes from the signed Consent Agreement and Final Order, dated April 2024.

“EPA further subsequently determined, in conversation with Respondent, that the sodium azide waste reported by Respondent was not, in fact, a ‘hazardous waste’ regulated under RCRA because it was not the ‘sole active ingredient’ in the process waste that Respondent generated. Respondent’s use of the P-list code P105 for this waste was erroneous.”

“EPA also subsequently determined, in conversation with Respondent, that Respondent had inadvertently reported a greater quantity of potassium cyanide waste than it had actually generated and disposed of. Although the amount identified on the manifest for this waste was two kilograms, Respondent had only generated and disposed of 0.025 kilograms of potassium cyanide in two 0.25-kilogram glass containers.”

“For the purpose of these proceedings, Respondent admits the jurisdictional allegations herein; however, the Respondent neither admits nor denies the specific factual allegations contained in this CAFO.”

“EPA’s conferral with Respondent established that the Respondent acted in good faith and that the Respondent complied with the vast majority of applicable regulatory requirements.”

“Respondent explicitly waives any right to contest the allegations or to appeal the proposed final order contained in this CAFO and waives all defenses that have been raised or could have been raised to the claims set forth in the CAFO.”

The Damage That Doesn’t Fit On A Check

Public Health

The RCRA manifest system is a public health tool. When it breaks down, the risks are invisible and distributed across everyone who touches the waste chain.

• Potassium cyanide is one of the most acutely toxic substances regulated under RCRA. A dose of less than a gram can be lethal to a human adult. The entire premise of the P-list system is that facilities handling these substances maintain flawless documentation so that transport workers, disposal facility employees, and first responders always know what they are dealing with. Tulane’s manifest listed 80 times the actual quantity of potassium cyanide disposed of, creating a document that did not reflect reality at any point in the disposal chain.
• Workers at the licensed treatment facility that received Tulane’s potassium cyanide waste operated under the assumption that the manifest was accurate. Federal law requires them to. If Tulane’s error had run in the other direction, with actual quantities exceeding what was reported, those workers would have had no way to know they were handling more of a lethal substance than their protocols anticipated.
• The sodium azide error represents a different failure. By labeling a non-hazardous waste with a P-list code, Tulane inflated the apparent hazard level of its disposal stream. This crowds the regulatory picture, directing attention and resources toward waste that does not require them, while the administrative error itself goes undetected for years.
• Community members living near the Covington facility had no mechanism to learn about these manifest errors until the EPA’s records review. Louisiana’s environmental regulatory history shows that communities in the vicinity of research facilities and industrial sites are disproportionately likely to be low-income and communities of color, with limited access to the legal or scientific resources needed to independently monitor facility compliance.

Economic Inequality

The $15,000 fine structure in this case illustrates a structural problem in federal environmental enforcement: the penalty is not calibrated to the wealth of the violator.

• Tulane University reported total revenues exceeding $1.5 billion in its most recent publicly available financial disclosures. A $15,000 fine against an institution of that scale functions as a rounding error, not a deterrent. It does not change the cost-benefit calculation for future compliance investment.
• RCRA’s civil penalty authority allows fines of up to $70,117 per day per violation under current federal guidelines. The single $15,000 assessment in this case represents a tiny fraction of the statutory maximum, and the EPA’s own document cites Tulane’s good-faith cooperation as a mitigating factor. The practical effect is that institutions with legal and administrative resources to cooperate effectively with EPA investigations pay less than those without.
• The compliance order requires Tulane to write new standard operating procedures and certify its waste streams. These are tasks any large institution with a functioning legal and compliance department can complete in 30 days. Smaller generators, community clinics, or small manufacturers facing similar violations may lack that infrastructure entirely, creating disparate compliance burdens that the fine schedule does not account for.
• There is no provision in the Consent Agreement for any community benefit, remediation fund, or third-party audit. The entire resolution flows between Tulane and the EPA. The residents of Covington, Louisiana receive nothing except a certified compliance letter filed with the Regional Hearing Clerk in Dallas, Texas.

What $15,000 Means In The Real World

The Watchlist And The Next Move

This case closed with a $15,000 check and a 30-day compliance window. Here is who has jurisdiction over Tulane’s ongoing operations, and here is what organized pressure actually looks like.

Named Parties in This Enforcement Action

• Mark A. Alise, MBA, PhD — Signed the Consent Agreement on behalf of Tulane University / Tulane National Primate Research Center on April 11, 2024.
• Cheryl T. Seager — Director, Enforcement and Compliance Assurance Division, U.S. EPA Region 6. Signed as Complainant.
• Thomas Rucki — Regional Judicial Officer, U.S. EPA Region 6. Issued the Final Order on April 12, 2024.
• Adolphus Talton — EPA Region 6 enforcement contact listed for compliance submissions and penalty notices (talton.adolphus@epa.gov).

The Watchlist: Who Oversees This Facility

• U.S. EPA Region 6 (Dallas, TX) — Primary RCRA enforcement authority. Filed this action. Has ongoing jurisdiction over all hazardous waste compliance at the Covington facility. Contact: Enforcement and Compliance Assurance Division, 1201 Elm Street, Suite 500, Dallas, TX 75270.
• Louisiana Department of Environmental Quality (LDEQ) — Louisiana has an EPA-authorized state hazardous waste program under RCRA. The state received notice of this enforcement action per RCRA Section 3008(a)(2). LDEQ has independent authority to act on violations within Louisiana.
• U.S. Department of Agriculture (USDA) — The Tulane facility is a USDA Class B licensed animal dealer. The USDA’s Animal and Plant Health Inspection Service (APHIS) oversees compliance with the Animal Welfare Act at licensed facilities.
• U.S. Department of Justice (DOJ) — The Final Order in this case explicitly preserves EPA and DOJ’s right to pursue injunctive relief or criminal sanctions for violations of law beyond those resolved by this settlement.

What Organized Pressure Looks Like Here

• Contact LDEQ directly and request the public file on Tulane National Primate Research Center’s hazardous waste generator history. Louisiana’s Public Records Law entitles residents to these documents. Submit written records requests to LDEQ’s Office of Environmental Services in Baton Rouge.
• Connect with environmental justice organizations already active in St. Tammany Parish and the greater Northshore Louisiana region. Groups monitoring industrial and research facility compliance in South Louisiana have established legal and organizing infrastructure that can route formal complaints into regulatory channels.
• File public comments with EPA Region 6 on future enforcement actions involving academic and research institutions. The settlement structure in this case, including the good-faith reduction and the absence of any community benefit provision, reflects an enforcement policy that can be challenged through the public comment process during proposed settlements.
• Track Tulane’s compliance certification. The CAFO required Tulane to submit written certification of compliance, including its new SOPs, within 30 days of the CAFO’s effective date (April 12, 2024). That certification is a public record. Request it from the Regional Hearing Clerk, Lorena Vaughn, at EPA Region 6, 1201 Elm Street, Suite 500, Dallas, TX 75270.
• Support mutual aid organizations in Covington and St. Tammany Parish that provide direct environmental health resources, air quality monitoring, and legal referral to community members who lack the institutional resources to monitor research facilities independently.