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The United States Environmental Protection Agency (“EPA”) and Gold Medal Service (“GMS”) entered into an April 7th Consent Agreement and Final Order (“CAFO”) addressing an alleged violation of the Clean Air Act regulations 40...more
When evaluating legal risk relating to per- and polyfluoroalkyl substances (“PFAS”), most businesses typically consider wastewater, groundwater, or soil impacts, not air emissions. However, state and federal regulatory...more
A few considerations practitioners should keep in mind when dealing with contamination involving per- and polyfluoroalkyl substances (PFAS) contamination. The PFAS Action Act of 2021 passed in the House and was received in...more
The U.S. Chemical Safety and Hazard Investigation Board (CSB) adopted regulations on February 21, 2020, under the Clean Air Act requiring the reporting of certain accidental releases. Their purpose is to enable the CSB to...more
On February 4, 2019, a federal court ruled that the U.S. Chemical and Safety Hazard Board must issue regulations within one year that set forth reporting requirements for accidental releases of hazardous substances into the...more
A trilogy of recent federal and state enforcement actions show just how far agencies will go to enforce environmental regulations. Now may be a good time for a compliance audit....more
Introduction - Let me be Captain Obvious here. When the title is that long, the topic, including its context and history, is convoluted. Let’s start at the end, work our way toward the beginning, and come full circle. On...more