Megan Baroni

Megan Baroni

I am an environmental attorney in Robinson+Cole’s Environmental and Utilities Group. I have worked with manufacturers, both big and small, on environmental compliance, risk management, and litigation matters for my entire career. My full firm bio can be accessed here.

As an environmental lawyer, I never want to be a roadblock to our client’s goals. I strive to understand the business of our manufacturing clients – what do you make and how do you make it? I want to know your objective, and I want to help you get there. Regulatory requirements and potential legal liabilities can sometimes seem daunting, but I help our clients develop an understanding of the requirements and all of the potential options so that we can create practical and cost-effective solutions to accomplish the objective. I work with management as well as the people who make our clients’ products every day, and I enjoy every part of it. It’s a good day for me when I can put on my hard hat and walk the factory floor.

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Significant Increase in OSHA Whistleblower Complaints and Caseloads Due to COVID-19

Thank you to my colleague, Jonathan Schaefer, for his contributions to this post. Jon focuses his practice on environmental compliance counseling, occupational health and safety, permitting, site remediation, and litigation related to federal and state regulatory programs. Since at least March, manufacturers, and the entire U.S. economy, have been experiencing unprecedented conditions as a result of the … Continue Reading

Virginia Issues First COVID-19 OSHA Standard

Thank you to my colleague, Jonathan Schaefer, for his contributions to this post. Jon focuses his practice on environmental compliance counseling, occupational health and safety, permitting, site remediation, and litigation related to federal and state regulatory programs. While Federal OSHA has issued numerous COVID-related guidance documents, it has declined to issue an enforceable COVID standard. Instead, OSHA … Continue Reading

OSHA Issues FAQs on Masks in the Workplace

Yesterday, OSHA issued guidance aimed at educating workers and employers on how to properly use face coverings at work during the COVID-19 pandemic. Structured as a series of frequently asked questions with answers, the guidance is the latest word from OSHA on measures workplaces can and should take to protect against the spread of COVID-19. … Continue Reading

OSHA Updates COVID-19 Guidance, Faces Lawsuit by AFL-CIO

As the country slowly begins the reopening process, OSHA has issued two new guidance documents—an Updated Interim Enforcement Response Plan for COVID-19 and Revised Enforcement Guidance for Recording Cases of COVID-19. Both documents go into effect on May 26, 2020, and both replace prior guidance documents adopted by OSHA on these topics. Updated Interim Enforcement … Continue Reading

Binge-Watching the Clean Water Act Cases and Rules

This week we are pleased to have a guest post from Robert S. Melvin, a member of Robinson+Cole’s Environmental, Energy + Telecommunications Group. Attorney Melvin has over 20 years of experience counseling clients on environmental, health, and safety compliance, sustainability, emergency response efforts, site remediation, and development projects. A wide range of clients benefit from … Continue Reading

Additional OSHA Guidance on COVID-19

OSHA previously issued guidance on preparing workplaces for COVID-19, which we covered on the blog a few weeks ago. The agency has been busy issuing additional materials to guide employers through these uncharted waters. A few recent developments are summarized below: Recordkeeping and Reporting Requirements OSHA has confirmed that COVID-19 can be a recordable work-related … Continue Reading

OSHA Issues COVID-19 Guidance for Workplaces

Last week, the Occupational Safety and Health Administration (OSHA) issued guidance on preparing workplaces for COVID-19. The guidance provides recommendations to help employers plan for the impact of COVID-19 on their businesses, workers, customers, and the public. While a number of states have implemented orders affecting certain workplaces, this guidance remains important for all employers to … Continue Reading

PFAS Update: EPA Progress Under PFAS Action Plan

Earlier this year, we wrote about EPA’s PFAS Action Plan, the agency’s blueprint for addressing contamination and protecting public health from per- and polyfluoroalkyl substances (PFAS). The PFAS Action Plan, released in February 2019, details a number of actions EPA plans to take with regard to PFAS, including time frames for implementation. EPA has been … Continue Reading

PFAS Update: EPA Progress Under PFAS Action Plan

Earlier this year, we wrote about EPA’s PFAS Action Plan, the agency’s blueprint for addressing contamination and protecting public health from per- and polyfluoroalkyl substances (PFAS). The PFAS Action Plan, released in February 2019, details a number of actions EPA plans to take with regard to PFAS, including time frames for implementation. EPA has been … Continue Reading

OSHA Approves New Respiratory Fit Testing Protocols

Thank you to my colleague, Jonathan Schaefer, for this post. Jon focuses his practice on environmental compliance counseling, occupational health and safety, permitting, site remediation, and litigation related to federal and state regulatory programs. Today OSHA issued a final rule approving two additional quantitative fit testing protocols for inclusion in appendix A of the Respiratory Protection Standard. … Continue Reading

EPA Formalizes Policy to Partner with States on Environmental Compliance and Enforcement

Over the summer, EPA published a policy document to enhance cooperation between it and the many state agencies that enforce federal environmental programs. The document formalizes a long-standing priority of this administration to, as we previously reported, “rebalance the power between Washington and the states to create tangible environmental results for the American people.” The … Continue Reading

Environmental Considerations in Corporate Transactions

My partner Bob Melvin and I recently gave a presentation on environmental, health, and safety considerations in mergers and acquisitions. While it would be impossible to cover our entire presentation in a blog post, I thought it would be good to highlight a few important environmental considerations in developing, negotiating, and finalizing corporate deals. Consider … Continue Reading

OSHA Seeking Public Comments on Lockout/Tagout Standards

Thank you to my colleague, Jonathan Schaefer, for this post. Jon focuses his practice on environmental compliance counseling, occupational health and safety, permitting, site remediation, and litigation related to federal and state regulatory programs. OSHA recently announced that it is considering whether it should revise the Control of Hazardous Energy (Lockout/Tagout (LOTO)) standard to accommodate recent technological advances … Continue Reading

OSHA Requesting Public Comment on Powered Industrial Truck Standards

OSHA recently announced that it is considering whether it should revise the powered industrial trucks standards for general, construction, and maritime industries. Powered industrial trucks include forklifts, fork trucks, motorized hand trucks, platform lift trucks, tractors, and other industrial trucks powered by an electric motor or internal combustion engine. The powered industrial trucks standards have … Continue Reading

TSCA Implementation Update: EPA Releases Updated Inventory and Delays Risk Evaluations

Thank you to my colleague, Emilee Mooney Scott, for this post. Emilee focuses her practice on chemicals and hazardous materials regulation and is counsel in our Environmental & Utilities Practice Group. As we previously outlined, the Toxic Substances Control Act (“TSCA”) was amended in 2016 to provide EPA with much broader authority to regulate “existing” chemical … Continue Reading

EPA Unveils PFAS Action Plan

On Valentine’s Day, EPA showed a little love for per- and polyfluoroalkyl substances (PFAS), announcing a sweeping plan to address PFAS contamination and protect public health. PFAS are a group of man-made chemicals that have been gaining a lot of attention, as described in our 2019 outlook. EPA Acting Administrator Andrew Wheeler announced the PFAS … Continue Reading

2019 Environmental, Health, and Safety Outlook For Manufacturers

This is the last of our three-part series of predictions for 2019. First Matt provided our thoughts and predictions in the labor/employment arena. Last week, Jeff gave our outlook for corporate compliance and litigation. Last but not least, this week I am providing our predictions for hot topics in environmental, health, and safety compliance, enforcement, and … Continue Reading

OSHA’s Use of Drones During Workplace Inspections

These days, it is not uncommon to see drones flying overhead. But employers beware…you might see one during your next workplace inspection. Earlier this year, OSHA issued a memo formalizing its use of drones for inspection activities, and, according to a recent report by Bloomberg Law, it used drones for 9 inspections this year. The … Continue Reading

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 safety, permitting, site remediation, and litigation related to federal and state regulatory programs. On October 17, 2018, the Occupational Health & Safety Administration (OSHA) announced the … Continue Reading

OSHA Clarifies Position On Anti-Retaliation Rule

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 safety, permitting, site remediation, and litigation related to federal and state regulatory programs. On October 11, 2018, the Occupational Health and Safety Administration (OSHA) issued a … Continue Reading

Monsanto Verdict Forewarns of Claims for Failure to Warn

By now, we have all heard about the $289 million verdict against Monsanto in the Roundup litigation. A California jury awarded the sum to Dewayne “Lee” Johnson, a school groundskeeper who claimed that exposure to Roundup contributed to his lymphoma. Johnson claimed that Monsanto’s product was defectively designed and that Monsanto failed to warn consumers … Continue Reading
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