Does your company manufacture domestically or import chemicals that the U.S. Environmental Protection Agency (EPA) is reviewing under section 6 of the Toxic Substances Control Act (TSCA)? Does your company submit applications...more
The U.S. Environmental Protection Agency's (EPA) June 2021 proposal of a Toxic Substances Control Act (TSCA) reporting rule targeting manufacturers of per- and polyfluoroalkyl substances (PFAS) sparked a major outcry from...more
In an announcement that expands the criteria for entry into the Occupational Safety and Health Administration’s (OSHA) Severe Violator Enforcement Program, OSHA has signaled that it is making enforcement a priority and that...more
The U.S. Environmental Protection Agency (EPA) has proposed to further amend its Clean Air Act Risk Management Program (RMP) rules and has issued a proposed rule. 87 Fed. Reg. 53556 (August 31, 2022). The proposed rule would...more
The Occupational Safety and Health Administration (OSHA) is not legally required to enforce its emergency temporary standard for the healthcare industry (Healthcare ETS), nor must it replace the Healthcare ETS with a...more
The U.S. Environmental Protection Agency (EPA) has proposed to further amend its Clean Air Act Risk Management Program (RMP) rules and has issued a proposed rule. 87 Fed. Reg. 53556 (August 31, 2022). The proposed rule would...more
Companies often submit confidential business information (CBI) to the U.S. Environmental Protection Agency (EPA) under the Toxic Substances Control Act (TSCA) with the expectation that EPA will not divulge that information to...more
EPA has proposed a ban on the ongoing uses of chrysotile asbestos, illustrating EPA’s strong authority under section 6 of the Toxic Substances Control Act (TSCA). Nevertheless, it is the alternatives to a ban that EPA...more
OSHA has officially withdrawn its COVID-19 vaccination and testing emergency temporary standard (ETS), 29 C.F.R. § 1910.501, per a notice in the January 26 Federal Register. 87 Fed. Reg. 3928 (Jan. 26, 2022). As explained in...more
The Supreme Court has put on hold the OSHA emergency temporary standard (ETS) on COVID-19 vaccination and testing. This stay will mean that OSHA probably cannot enforce the ETS prior to its expected expiration in May. OSHA...more
A year into the Biden Administration’s implementation of the 2016 amendments of the Toxic Substances Control Act (TSCA), EPA is planning an ambitious suite of actions under sections 4, 5, 6, 8, 14, and 23. Companies and trade...more
One in, one out, one in again.
One in: Employers with 100 employees or more should be prepared to comply with OSHA’s emergency temporary standard (ETS) that would require them to have their employees fully vaccinated or...more
1/4/2022
/ Coronavirus/COVID-19 ,
Employer Liability Issues ,
Employer Mandates ,
Health and Safety ,
Healthcare Workers ,
Infectious Diseases ,
OSHA ,
Popular ,
Vaccinations ,
Virus Testing ,
Workplace Safety
More than four years after finalizing reporting requirements for the manufacture, import, export, processing, and distribution in commerce of elemental mercury and mercury-added products, EPA has eliminated an exemption for...more
The U.S. Occupational Safety and Health Administration (OSHA) has issued a new emergency temporary standard (ETS) that requires employers with 100 or more employees to mandate that all employees be vaccinated against COVID-19...more
Following up on the short-term extension that it issued in September, EPA has issued a notice of proposed rulemaking that will further extend the compliance deadline for the processing and distribution in commerce of certain...more
October 26, 2021 Update:
Following up on the short-term extension that it issued in September, EPA has issued a notice of proposed rulemaking that will further extend the compliance deadline for the processing and...more
EPA has issued a prepublication version of a final rule to extend the submission deadline for the TSCA Health and Safety Data Reporting rule to December 1, 2021 for the 20 High Priority Substances, and to January 25, 2022 for...more
Updated September 17, 2021:
EPA continues to extend a key compliance deadline for PIP (3:1). In a final rule effective September 17, 2021, EPA delayed enforcing compliance with the ban on processing and distributing PIP...more
Employers with 100 or more employees should expect a new emergency temporary standard (ETS) from the Occupational Safety and Health Administration (OSHA) requiring them to mandate that all employees be vaccinated against...more
OSHA has updated its guidance on workplace protections for unvaccinated and otherwise at-risk workers who are not covered by the COVID-19 Emergency Temporary Standard (ETS) for Healthcare. The updated guidance, issued August...more
Key Takeaways:
• On July 7, 2021, OSHA issued revisions to its National Emphasis Program for COVID-19, DIR 2021-03 (CPL 03) (“Revised COVID-19 NEP”), and released an Updated Interim Enforcement Response Plan for...more
Section 8(d) of the Toxic Substances Control Act (TSCA) had been effectively a dead provision of TSCA for over a decade. EPA has just revived it by adopting an immediate final rule mandating the submission of health and...more
Do any of the articles, or article components, that your company imports contain PFAS? If so, your company may become subject to extensive reporting requirements proposed by EPA under the Toxic Substances Control Act (TSCA)....more
Over the last two months, the California Occupational Safety & Health Standards Board (“Board”) has considered several versions of proposed updates to the emergency temporary COVID-19 standards that were first adopted in...more
Vermont now has a law restricting per- and polyfluoroalkyl substances (PFAS) in a variety of products. After unanimous approval by both houses of the Vermont legislature, Governor Phil Scott signed into law S.20, an act that...more