News & Analysis as of

Recordkeeping Requirements Manufacturers

Williams Mullen

TSCA Test Marketing Exemption for New Chemicals: A Recent Case Study

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On July 24, 2025, U.S. Environmental Protection Agency (EPA) approved a Test Marketing Exemption (TME) under section 5(h)(1) of the Toxic Substances Control Act (TSCA) for a confidential new chemical substance (TME...more

BakerHostetler

The Delayed, but Not Forgotten, Disclosure of PFAS: TSCA Section 8(a)(7) Postponed While States Fill the Gaps

BakerHostetler on

When Congress passed the fiscal year 2020 National Defense Authorization Act (“NDAA”), it included a mandate that the U.S. Environmental Protection Agency (“EPA”) take steps to require all manufacturers, including importers,...more

Perkins Coie

Compliance Deadline Set for California’s Truth in Recycling Law, SB 343

Perkins Coie on

A significant development has occurred regarding California’s SB 343, which imposes strict new requirements on recyclability claims for products and packaging sold in the state. The California Department of Resources...more

Bergeson & Campbell, P.C.

EPA Reopens Comment Period on Proposed Risk Management Rule for PV29

On March 4, 2025, the U.S. Environmental Protection Agency (EPA) announced that it is reopening the comment period for the January 2025 proposed rule to address the unreasonable risk of injury to human health presented by...more

Littler

Cal/OSHA Approves Final Respirable Crystalline Silica Regulation, While Other Potential Limits on Engineered Stone Remain Under...

Littler on

On December 19, 2024, the Cal/OSHA Standards Board unanimously approved a proposal to make permanent amendments to its regulation regarding occupational exposures to respirable crystalline silica (RCS) in the general industry...more

ArentFox Schiff

FDA Issues New Cosmetics Proposed Rule: Let’s Talk About Talc

ArentFox Schiff on

Two years after the enactment of the Modernization of Cosmetics Regulation Act of 2022 (MoCRA), the US Food and Drug Administration (FDA) has published the long-awaited proposed rule on talc-containing cosmetics....more

Whiteford

Employment Law Update: Immigration Challenges Await Employers In 2025

Whiteford on

Immigration policy, in one form or another, touches virtually every business in the United States. All employers are subject to the requirements of the 1986 Immigration Reform and Control Act, which established the I-9...more

Shipman & Goodwin LLP

Required Historical PFAS Reporting Poses Risks Going Forward

Shipman & Goodwin LLP on

The U.S. Environmental Protection Agency recently established a one-time per- and polyfluoroalkyl substances reporting rule pursuant to the federal Toxic Substances Control Act. Pursuant to the rule, most companies that...more

Nilan Johnson Lewis PA

PFAS Reporting Requirements at the Federal and State Level – How Will Manufacturers Respond? – Part 4 of 10

Part 4. PFAS Reporting Requirements at the Federal and State Level – How Will Manufacturers Respond? Per- and polyfluoroalkyl substances, known by the acronym PFAS and better known by the moniker “forever chemicals,” are...more

Pillsbury Winthrop Shaw Pittman LLP

The EU’s AI Act: A Review of the World’s First Comprehensive Law on Artificial Intelligence and What This Means for EU and Non-EU...

The agreed text of the AI Act was published on July 12, 2024, essentially starting the clock on the legal deadlines contained in it. Its obligations will apply in tiered phases, with the first key obligations being enforced...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Air Enforcement: Arkansas Department of Energy & Environment - Division of Environmental Quality and Searcy Plastic Package...

The Arkansas Department of Energy & Environment – Division of Environmental Quality (“DEQ”) and The Bryce Company, LLC (“Bryce”) entered into an October 3rd Consent Administrative Order (“CAO”) addressing alleged violations...more

Steptoe & Johnson PLLC

Hazard Alert! Don’t Ignore OSHA’s Updated Electronic Submission Requirements for Employers

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Effective January 1, 2024, the Occupational Safety and Health Administration’s (OSHA) new record-keeping rule will now require employers with 100 or more workers in OSHA’s “highest hazard” industries to electronically file...more

Venable LLP

Prepare Now for the New FDA Requirements for Cosmetics Companies

Venable LLP on

Thanks to the Food and Drug Omnibus Reform Act (FDORA), cosmetic companies will soon be subject to new requirements for registration, product listing, disclosure of ingredients, adverse event reporting, safety substantiation,...more

MoFo Life Sciences

Congress Expands FDA Authority Over Cosmetics Regulation

MoFo Life Sciences on

The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) was passed by the U.S. Congress as part of the omnibus Consolidated Appropriations Act enacted on December 29, 2022 and will grant the U.S. Food and Drug...more

Bergeson & Campbell, P.C.

EPA Proposes TSCA Reporting and Recordkeeping Requirements for Asbestos

On May 6, 2022, the U.S. Environmental Protection Agency (EPA) proposed reporting and recordkeeping requirements for asbestos under Section 8(a) of the Toxic Substances Control Act (TSCA). 87 Fed. Reg. 27060. EPA proposes to...more

Fisher Phillips

Snapshot on Manufacturing Industry: OSHA Inspection Tracker

Fisher Phillips on

Welcome to FP Snapshot on Manufacturing Industry, where we take a quick snapshot look at the most significant workplace law developments over the past month with an emphasis on how they impact manufacturers. This snapshot is...more

McDermott Will & Schulte

FDA Issues Proposed Rule to Amend Medical Device Quality System Regulation

The US Food and Drug Administration (FDA) published its Medical Devices; Quality System Regulation Amendments proposed rule to amend the medical device Quality System Regulation (QSR) on February 23, 2022. While FDA generally...more

Husch Blackwell LLP

OSHA Issues New Guidance Applicable To All Employers Not Covered By The ETS

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On June 9, 2021, the Occupational Health and Safety Administration (OSHA) issued a new COVID-19 Emergency Temporary Standard (ETS) with the scope of the ETS limited to certain workplace settings that are defined as healthcare...more

Davis Wright Tremaine LLP

Reminder: FCC Accessibility Recordkeeping Certification Required by April 1, 2021

On March 4, 2021, the Federal Communications Commission (FCC) released a Public Notice to service providers and equipment manufacturers as a reminder to maintain records on compliance efforts to make their technology...more

Williams Mullen

EPA Amends TSCA Definition of “Small Manufacturer”

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EPA recently issued a final rule amending Toxic Substances Control Act (TSCA) regulations concerning “small manufacturers” of chemical substances. Companies that meet the regulatory definition of a “small manufacturer” of...more

Seyfarth Shaw LLP

FDA Eases Enforcement to Expand Remote Care of Pets and Food-Producing Animals

Seyfarth Shaw LLP on

On March 24, 2020, the US Food and Drug Administration (“FDA”) issued Guidance[1] suspending the enforcement of certain veterinarian-client-patient relationship (“VCPR”) requirements to help veterinarians provide animal...more

Bergeson & Campbell, P.C.

Communication and Recordkeeping Requirements Related to EPA Ban on Consumer Use Paint Removers Containing Methylene Chloride Go in...

In the March 27, 2019, Federal Register, the U.S. Environmental Protection Agency (EPA) issued its final regulatory rulemaking that prohibits the manufacture (including import), processing, and distribution of methylene...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Air Enforcement: Alabama Department of Environmental Management and Sumter County, Alabama, Aggregate Manufacturing Facility Enter...

The Alabama Department of Environmental Management (“ADEM”) and Arcosa LW BR, LLC, (“Arcosa”) entered into a February 8th Consent Order (“CO”) addressing alleged violations of an air permit. The CO provides that Arcosa...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Hazardous Materials Regulations Revisions: U.S. Pipeline and Hazardous Materials Safety Administration Addresses Industry...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) issued a November 7th final rule amending the federal Hazardous Materials Regulations (“HMR”). See 83 Fed. Reg. 55792. The Hazardous...more

Robinson+Cole Manufacturing Law Blog

OSHA Launches New Inspection Targeting Program

Thank you to Jonathan Schaefer for this post. Jon is an attorney in our Environmental, Energy & Telecommunications Practice Group and his practice focuses on environmental compliance counseling, occupational health and...more

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