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California Supreme Court Allows Unfair Competition and False Advertising Claims Against Employer Arising From Workplace Accident

A recent California Supreme Court decision held that employees can sue their employers for workplace safety violations under the State’s consumer protection laws. See Solus Industrial Innovations, Inc. v. Superior Court of...more

EPA’s Formaldehyde Standards: Compliance Date Moved Up to June 1, 2018

June 1, 2018 will be the initial compliance date for most companies in the composite wood product industry that are subject to EPA’s Formaldehyde Emission Standards for Composite Wood Products (the Standards). On April 4,...more

Get Ready for Compliance: Recent Updates on EPA’s Formaldehyde Emission Standards for Composite Wood Products

The composite wood product industry may face an earlier compliance deadline under EPA’s Formaldehyde Emission Standards for Composite Wood Products (Standards) than the deadline currently set by EPA. On February 16, 2018, a...more

TSCA Reform Implementation and Expected 2018 Developments

Some 20 months have passed since the Frank R. Lautenberg Chemical Safety for the 21st Century Act (LCSA) was signed into law, making wide and significant changes to the Toxic Substances Control Act (TSCA). During that time,...more

Ninth Circuit Orders EPA to Update Standards for Lead-Based Paint and Dust Hazards

The Environmental Protection Agency (EPA) must propose an update of its lead-based paint and dust hazard standards by March 27, 2018, according to a court order. The current standards were promulgated in 2001, and have never...more

Washington OSHA Issues Draft PSM Rule for Refineries

The Washington Department of Labor and Industries’ Division of Occupational Safety and Health (DOSH) recently released a new draft safety rule that would increase existing Process Safety Management (PSM) requirements for...more

D.C. Circuit Rejects Industry Challenges to Silica Rule and Remands to OSHA for Further Consideration on Medical Removal...

The U.S. Court of Appeals for the District of Columbia rejected all industry challenges to an Obama-era rule on worker exposure to respirable crystalline silica in a December 22, 2017 ruling. In its written decision, the...more

TSCA Mercury Inventory Reporting Rule: Latest Piece of EPA’s Mercury Regulation

EPA has extended the December 26, 2017 deadline for comments on its proposed rule on reporting obligations relating to mercury, mercury compounds, and mercury-added products until January 11, 2018. The proposed rule was...more

California Approves New Amendments to Proposition 65 Safe-Harbor Regulations

The California Office of Environmental Health Hazard Assessment (OEHHA) announced on December 6, 2017 that the state had approved new amendments (Final Amendments) to the Proposition 65 Clear and Reasonable Warning...more

States Continue to Enact Chemical Legislation in 2017

State legislatures have been relatively active on chemical and material regulations in 2017. As previously reported here, at least 51 bills to regulate chemicals were introduced across the country’s state houses in 2017. ...more

Competing Cosmetic Safety Bills Would Each Expand FDA Regulatory Authority

On October 25, 2017, Senator Orin Hatch (R-UT) introduced S. 2003, the “FDA Cosmetic Safety and Modernization Act.” The proposed legislation would amend the Federal Food, Drug and Cosmetic Act of 1938 (“FFDCA”) and allow the...more

OSHA Delays First Deadline for Electronic Reporting to December 15, 2017

On November 24, 2017, OSHA published a final rule in the Federal Register delaying the initial compliance deadline for the electronic submission of worker injury and illness logs to December 15, 2017. By December 15, all...more

The Mexichem Conjecture: Regulating HFCs under CAA ... or TSCA?

Since 1994, EPA has regulated hydrofluorocarbons (HFCs), which are potent greenhouse gases, through several programs under Title VI of the Clean Air Act (CAA) governing stratospheric ozone protection. In a recent decision,...more

EPA Publishes Background Documents for Five PBT Chemicals, Hosting Webinar in Early September

Persistent, bioaccumulative, and toxic chemicals (PBTs) receive expedited attention under the amended Toxic Substances Control Act (TSCA). The Environmental Protection Agency (EPA) recently released background documents for...more

EPA Releases Final Guidance on TSCA Section 8(a) Nanomaterial Reporting Rule

The Environmental Protection Agency (EPA) released the Working Guidance on EPA’s Section 8(a) Information Gathering Rule on Nanomaterials in Commerce (Guidance) on August 14, 2017. EPA developed the final Guidance based on a...more

The TSCA Inventory Reset Begins

Virtually all manufacturers and importers of chemicals for the past 11 years are now subject to a new TSCA reporting requirement known informally as the TSCA Inventory Reset. Reports are due by February 7, 2018. All...more

EPA Releases TSCA Final Rule on Prioritization of High-Priority and Low-Priority Chemical Substances

Under the amended TSCA, prioritization – EPA’s process for selecting which chemical substances to evaluate for possible regulation – is the gatekeeper. EPA has just adopted a final rule describing its process for selecting...more

The TSCA Inventory Reset Clock to Start Ticking

Virtually all manufacturers and importers of chemicals for the past 11 years are now subject to a new TSCA reporting requirement known informally as the TSCA Inventory Reset. Reports will be due six months after the final...more

EPA’s Risk Evaluation Framework Rule Incorporates Key Industry Suggestions

Under the 2016 TSCA amendments, risk evaluation is the critical step toward EPA banning or restricting chemicals, or else determining that they will not be regulated. As required by those amendments, EPA has promulgated a...more

Unique Identifiers: A Little-Noticed TSCA Provision Could Have a Big Impact on CBI

Protection for confidential business information (CBI) could be at risk under one provision of the amended Toxic Substance Control Act (TSCA) now under consideration by EPA. TSCA’s little-noticed section 14(g)(4) requires...more

OSHA Proposes December 1, 2017 Deadline for First Phase of Electronic Reporting, Foreshadows Rulemaking on Anti-Retaliation...

On June 28, 2017, OSHA published a proposed rule in the Federal Register delaying the initial compliance deadline for the electronic submission of worker injury and illness logs to December 1, 2017. This proposal comes...more

EPA Delays Effective Date of RMP Rule Amendments, Environmental Groups File Challenge

On June 14, 2017, EPA published a final rule in the Federal Register delaying the effective date of its Risk Management Program (RMP) rule amendment package for twenty months, until February 19, 2019. EPA’s decision was...more

OSHA Indefinitely Delays Electronic Reporting Requirements

Last week, the Labor Department indefinitely delayed enforcement of at least the first phase-in deadline of its electronic reporting requirements for injury and illness logs. Specifically, OSHA’s Injury and Illness...more

TSCA Nanomaterial Reporting Rule: EPA Delays Effective Date and Releases Draft Guidance for Public Comment

The U.S. Environmental Protection Agency (“EPA”) issued its Draft Guidance on EPA’s Section 8(a) Information Gathering Rule on Nanomaterials in Commerce ( “Draft Guidance”) on May 16, 2017. See 82 Fed. Reg. 22452 (May 16,...more

OSHA’s “Volks” Rule Invalidated

Last week, President Donald Trump signed a joint resolution passed by the House and Senate overturning the Occupational Safety and Health Administration (“OSHA”) rule titled “Clarification of Employers’ Continuing Obligation...more

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