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Update on Vaccine Requirements and Roll Out of the Path out of Pandemic Plan

We have been answering a number of questions from clients regarding the nature and scope of the requirements for COVID vaccination, testing, masking and more. Our previous alert and blogs laid out the administration's Path...more

How Can We Chart a Course on Navigable Waters?

Since the U.S. Supreme Court decided the County of Maui v. Hawaii Wildlife Fund case in April 2020, the legal landscape of "navigable waters of the U.S." has eroded quickly. With Maui, the Supreme Court created a test for...more

Biden Administration Announces Heat-Related Hazard Inspection Initiative, Upcoming Rulemaking

As part of the Biden Administration's efforts to protect workers, the White House announced formal efforts to address heat-related illnesses. The first step is OSHA's recent memo establishing an enforcement initiative to...more

Clean Water Requirements Escalate for PFAS, Nutrients and other Pollutants

On September 8, the Environmental Protection Agency (EPA) announced its Preliminary Effluent Guidelines Program Plan 15, which includes a suite of actions designed to address wastewater pollution under the Clean Water Act....more

President Biden Sets Stage for Workplace Vaccination Game Changer

On September 9, 2021, President Biden announced major actions intended to combat the spread of the COVID-19 pandemic called the Path Out of the Pandemic that will have a significant impact on employers across the country. ...more

OSHA (Finally) Issues COVID-19 ETS Applicable to Healthcare Industry Along with Updated Guidance for All Workplaces

At long last, the Occupational Safety and Health Administration (OSHA) issued its Emergency Temporary Standard (ETS), after the Office of Management and Budget concluded stakeholder meetings on Wednesday, June 9. ...more

Proceed with Caution: Local Orders Lifting Mask Mandates Are Not Blanket Permission Slips to Eliminate Safety Protocols in...

In response to the Centers for Disease Control and Prevention's (CDC) May 13 update of two key guidance documents that now show fully vaccinated people no longer need to wear a mask or physically distance, local and state...more

OSHA Launches National Emphasis Program and Revises Enforcement Procedures Related to COVID-19

As mandated in President Biden's January 21 Executive Order on Protecting Worker Health and Safety, the Department of Labor (DOL) on March 12 issued the latest piece of the puzzle with a National Emphasis Program –...more

Keep the Face Coverings On: Safe Workplace Considerations Remain as Mask Mandates Lifted

On March 1, Texas Governor Greg Abbott rescinded the state-wide executive orders requiring face coverings and creating business operational restrictions. Effective March 10, 2021, the mask mandate will be lifted and...more

DOJ Puts Supplemental Environmental Projects Back on the Negotiating Table

The Biden administration hit the ground running on its initiative to "confront the climate crisis." On January 20, 2021, President Biden signed Executive Order 13,990 (EO), which directed all federal agencies to "immediately...more

OSHA Issues First New General Workplace Guidance since June 2020

As mandated in President Biden's Executive Order on Protecting Worker Health and Safety, on January 29, OSHA issued a new guidance document, Protecting Workers: Guidance on Mitigating and Preventing the Spread of COVID-19 in...more

Tracking Environmental Midnight Rules as the Clock Ticks down on the Trump Administration

With a new year approaching, so does the imminence of a new presidential administration. The Biden team and transition team have laid out environmental policies since early in the campaign....more

New Order from Arizona Governor and New OSHA Guidance Put Multi-State Employers in a Quandary with Reopening Plans

Arizona Executive Order - Arizona’s Governor Doug Ducey issued an executive order laying out efforts to contain the spread of COVID-19. This executive order follows a spike in confirmed COVID-19 cases after Arizona...more

New OSHA COVID-19 Construction Guidance: How Does it Impact Your Job Site?

16,000 nationwide complaints to OSHA agencies since April prompt sector-specific guidance - OSHA continues to publish new COVID-19 guidance, including issuance of a recent construction work guidance on May 26. As employee...more

Kansas Act Purports to Provide Immunity from COVID-19 Related Claims

On June 4, 2020, the Kansas Legislature passed the COVID-19 Response and Reopening for Business Liability Protection Act. It now goes to Governor Laura Kelly for signature....more

As Agencies Issue Updated Coronavirus Guidance, Existing Policies Should Be Evaluated and Updated

The CDC, OSHA and other local, state and federal agencies continue to rapidly issue and modify guidance related to COVID-19. As states are in various phases of reopening, employers must continue to keep a watchful eye and...more

Return-to-Work Best Practices During the COVID-19 Pandemic

As the curve of COVID-19 infections begin to level off, employees recover from infections, and as government shelter-in-place and similar orders begin to expire, businesses are confronted with the complexities of returning...more

Working with Environmental Agencies When Managing Business Impacts from COVID-19

Since the COVID-19 pandemic, federal, state and local agencies have adapted their procedures to both working remotely and allowing certain flexibilities for companies if specific efforts are made. ...more

Supreme Court Reverses EPA in Key CWA Groundwater Case

This week, the U.S. Supreme Court issued its long-awaited opinion in County of Maui v. Hawaii Wildlife Fund, regarding whether the discharge of pollutants via groundwater requires a Clean Water Act (CWA) permit. This holding...more

OSHA Considerations for Employers Deciding Whether to Require or Allow Use of Face Masks in the Workplace

The Centers for Disease Control and Prevention (CDC) recently recommended the use of cloth face coverings in public as an “additional, voluntary public health measure” to slow the spread of COVID-19. ...more

DOL Issues Temporary Rule Promulgating Regulations on the FFCRA

On April 1, 2020 the U.S. Department of Labor (DOL) issued a temporary rule promulgating regulations on the Families First Coronavirus Response Act (FFCRA), which created two new emergency paid leave requirements in response...more

DOJ Terminates Use of Supplemental Environmental Projects

On March 12, 2020, the U.S. Department of Justice's Environment and Natural Resources Division (ENRD) published a memorandum that ceases the future use of Supplemental Environmental Projects (SEP) in settlement agreements to...more

FDA Issues Temporary Policy to Address Hand Sanitizer Shortage

FDA recently issued two immediately effective guidance documents to help increase the availability of hand sanitizer to the public and health care personnel due to shortages brought about by the COVID-19 pandemic. One of the...more

Recent Executive Orders Take Aim at Informal Agency Guidance

Earlier this month the Trump Administration issued two executive orders limiting federal agencies’ use of informal guidance documents to regulate conduct. "Informal guidance documents" are generally understood to include...more

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