A-901 • WASTE HAULING • SOIL & FILL RECYCLING
A Regulatory Question Can Put an Entire Waste Business at Risk.
For waste haulers, recyclers and soil/fill businesses, licensing and commercial operations can be closely connected. An A-901 question, proposed ownership change or disputed vendor agreement may affect the right to operate or retain customers. BOLO advises selected New Jersey businesses on licensing notices, transactional documents and disputes, focusing on the actual company structure and agency requirements.
New Jersey-based attorney • Investigation and business-counseling experience • Representation evaluated matter by matter
Business counsel before, during and after a regulatory event.
Your company needs more than crisis response. BOLO offers document reviews, a recurring outside-counsel relationship and separately scoped regulatory or commercial defense. Choose the next step that fits the business.
Operate & Protect
Legal Baseline, monthly plans, document library and recurring counsel.
Respond & Defend
Investigations, agency notices, licensing issues and business disputes.
A-901 INTEGRITY AND LICENSING
An A-901 inquiry deserves a disclosure-by-disclosure review.
A-901 issues can reach company ownership, control, key employees, parent-company filings and business arrangements. These resources explain the response process.
WHEN SOMETHING IS ALREADY WRONG
Treat a licensing or integrity inquiry as a major business event.
A question about ownership, key employees, disclosures, business conduct, or compliance may have consequences beyond a particular facility. Before submitting a response or restructuring, identify the scope of the notice, the covered entities, and the supporting record.
First steps worth considering
- Preserve the agency notice, applications, ownership schedules, annual updates, and correspondence.
- Identify each entity, principal, and facility implicated by the inquiry.
- Separate waste-industry licensing questions from site permits, transportation, and contractual concerns.
- Inventory responsive records without altering documents or creating misleading summaries.
- Have counsel review deadlines and the planned response before it is sent.
LEGAL SERVICES
Support for businesses operating under multiple kinds of risk
Licensing, environmental issues, ownership relationships, and commercial agreements can overlap. Representation is tailored to the actual A-901 and related legal questions presented.
A-901 & Integrity Inquiries
Assess notices, licensing disclosures, ownership and key-person questions, regulatory correspondence, and potential administrative proceedings.
Investigations & Enforcement Response
Organize documents, factual chronologies, agency communications, and defense options when allegations or inspection findings arise.
Hauling, Brokering & Supply Contracts
Advise on service agreements, subcontracting, supplier relationships, payment claims, risk allocation, and disputes between operating companies.
Ownership Changes & Ongoing Counsel
Evaluate selected transactions, principal changes, business governance, and risk controls alongside specialists when environmental or technical matters require them.
THE REGULATORY LANDSCAPE
A-901 is not ordinary business registration.
NJDEP identifies A-901 as a licensing framework for covered waste businesses and soil and fill recycling services. It administers the program with involvement from the New Jersey Office of the Attorney General and State Police to evaluate integrity, reliability, expertise, and competence.
Different operators can face different requirements
Covered transporters, brokers, facilities, and soil/fill recycling service providers have distinct factual situations. License requirements and exemptions should be evaluated rather than assumed.
Disclosures and background review matter
The background and integrity review extends beyond the name on a truck or contract. A company’s ownership and management structure may be material.
Site and environmental issues may require separate specialists
A-901 issues can coexist with NJDEP permitting, contamination, transportation, and environmental remediation questions; technical environmental counsel may be necessary.
Agency requirements vary by license, business model, and the specific facts. General information here is not individualized legal advice.
EXPERIENCE THAT TRANSLATES
Investigative experience. Business-minded counsel.
BOLO Health Law is led by Brian O’Loughlin, a New Jersey attorney, former New Jersey Deputy Attorney General, and former healthcare program-integrity investigator. That background informs document review, risk evaluation, agency interactions, litigation strategy, and direct communication with business owners.
Prior investigative work was in healthcare program integrity and public-corruption/white-collar matters, not as a regulator of this industry. Sector-specific technical counsel or local co-counsel may be engaged when appropriate.
An active enforcement or licensing matter
We start by identifying the notice, deadlines, decision-makers, facts, records, and authorized scope of representation.
A longer-term business relationship
We can discuss contracts, governance, vendor issues, ownership changes, operational risk, and an outside-counsel arrangement.
QUESTIONS BUSINESS OWNERS ASK
Common questions
Can you evaluate an NJDEP A-901 inquiry?
Yes, BOLO can review the notice and underlying business facts to determine appropriate representation and whether A-901-specific co-counsel is warranted.
What if an ownership or principal change is planned?
Bring counsel into the transaction early. Applicable licensing and disclosure obligations should be evaluated before terms are finalized.
Is A-901 coverage the same for every recycler?
No. The regulatory status depends on the precise operation, material, and legal classification. The current NJDEP guidance controls.
Official regulator information
The NJDEP A-901 Unit publishes requirements and contact information for waste and soil/fill recycling licensees.
TALK WITH BOLO
Tell us what is threatening your business, or what you want to build.
Give a brief, nonconfidential description of your company, the agency or transaction involved, and any known deadline. If a deadline is imminent, call 609-200-6677; online messages may not be reviewed immediately.
Attorney advertising. No outcome is guaranteed. All matters require conflict, admissions, and engagement review. BOLO Health Law L.L.C., New Jersey.