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TSCA Implementation Update: EPA Finalizes Framework Rules and Announces Scope For First Risk Evaluations

TSCA Framework Rules Promulgated - As we outlined last year, the Toxic Substances Control Act (“TSCA”) was recently updated to provide EPA with much broader authority to regulate “existing” chemical substances (i.e., those...more

Superfund Changes Afoot

Since taking over as EPA Administrator, Scott Pruitt has made it clear that he intends to focus on—and overhaul—the Superfund program. Calling the program “at the center of the Agency’s core mission”, Pruitt has put in place...more

EPA Identifies First Ten Chemical Substances For Evaluation Under New TSCA

As we outlined earlier this year, the Toxic Substances Control Act (“TSCA”) was recently updated to provide EPA with much broader authority to regulate “existing” chemical substances (i.e., those that are already in use in...more

EPA Turns Up the Heat on Refrigerant Regulation

Refrigeration and cooling systems face expanded and tighter regulation under a final rule recently signed by EPA Administrator Gina McCarthy. The rule revises and expands EPA’s regulations for “Ozone-Depleting Substances”...more

EPA Turns Up the Heat on Refrigerant Regulation

Refrigeration and cooling systems face expanded and tighter regulation under a final rule recently signed by EPA Administrator Gina McCarthy. The rule revises and expands EPA’s regulations for “Ozone-Depleting Substances”...more

The Chemistry Was Right For TSCA Reform

In a rare bipartisan effort, Congress overwhelmingly passed a bill significantly reforming the chemical safety provisions of the Toxic Substances Control Act (“TSCA”) for the first time in its forty-year history. The Frank...more

Environmental, Health & Safety – What to Watch in 2016

To round out our series on industry and legal outlooks for 2016, I have compiled some of the many things for manufacturers to be aware of in the Environmental Health & Safety world for 2016....more

EPA To Propose Overhaul of RCRA Generator Regulations

EPA is poised to publish a proposed rule revising regulations applicable to hazardous waste generators under the Resource Conservation and Recovery Act, 42 U.S.C. § 6901 et seq. (RCRA). The proposed rule, which has not yet...more

Does Next Generation Compliance Mean Expanded Enforcement?

EPA is in the process of rolling out Next Generation Compliance, or NextGen, in an effort to make its programs more effective, facilitate compliance, and, ultimately, enhance environmental benefit.  But in many ways, NextGen...more

Major Expansion of EPA Rules for Underground Storage Tanks

On July 15, 2015, the United States Environmental Protection Agency (EPA) published a final rule significantly expanding its program for underground storage tank (UST) systems that store petroleum or hazardous substances....more

Disclosing Violations to EPA in a Digital Age

Under EPA’s Audit Policy and Small Business Compliance Policy, companies that discover, promptly disclose, and expeditiously correct environmental violations may be entitled to penalty mitigation and other incentives. EPA...more

Superfund Divisibility Defense Gets New Life

The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as Superfund, is a federal law under which contaminated sites are identified and evaluated by the Environmental Protection...more

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