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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OSHA Requesting Public Comment on Powered Industrial Truck Standards

By Megan Baroni on April 5, 2019 Posted in OSHA Compliance

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

By Megan Baroni on March 8, 2019 Posted in Chemical Regulation

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

By Megan Baroni on February 15, 2019 Posted in Environment, Environmental Compliance & Permitting, Environmental Enforcement, Environmental Rulemaking

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

By Megan Baroni on January 25, 2019 Posted in Environment, Environmental Compliance & Permitting, Environmental Enforcement, Health & Safety, OSHA Compliance

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

By Megan Baroni on December 7, 2018 Posted in OSHA Compliance

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

By Megan Baroni on October 25, 2018 Posted in OSHA Compliance

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

By Megan Baroni on October 12, 2018 Posted in OSHA Compliance

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

EPA Lists First Sites to NPL for Vapor Intrusion

By Megan Baroni on September 20, 2018 Posted in Environmental Enforcement

Last week, EPA added two sites to the National Priorities List (NPL), a list of sites of national priority for known or threatened releases of hazardous substances, solely for the risks posed by vapor intrusion. Vapor intrusion, a topic previously covered on our blog, is the migration of volatile chemicals from soil or groundwater into … Continue Reading

Monsanto Verdict Forewarns of Claims for Failure to Warn

By Megan Baroni on August 22, 2018 Posted in Chemical Regulation, Environment, Litigation

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

Climate Change Nuisance Lawsuit Dismissed

By Megan Baroni on June 29, 2018 Posted in Environment, Litigation

This week, a California federal court dismissed a lawsuit brought by two cities against a number of large oil companies seeking to force the companies to fund the cities’ climate change adaptation efforts. The Court held that, while the science behind global warming is real, the problem must be solved by the legislative and executive … Continue Reading

EPA to Rethink Cost-Benefit Analyses During Rulemaking Process

By Megan Baroni on June 8, 2018 Posted in Environment, Environmental Rulemaking

This week, EPA announced that it is considering developing regulations to optimize the use of cost-benefit analyses when it is taking regulatory action. Many environmental statutes require the consideration of costs and benefits to evaluate the impacts of policy choices. EPA is seeking public comment on whether and how these analyses can be made more … Continue Reading

Failed to File An Electronic Injury Report? OSHA May Be Looking For You

By Megan Baroni on April 6, 2018 Posted in OSHA Compliance

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. Under the 2016 Recording and Reporting Occupational Injuries and Illnesses rule … Continue Reading

EPA Considering Ban On The Use Of Private Scientific Data

By Megan Baroni on March 30, 2018 Posted in Environment, Environmental Compliance & Permitting

EPA Administrator Scott Pruitt is considering a plan to restrict the agency’s use of scientific data to only that data which is publicly available. The move would prevent EPA from using private studies, dubbed “secret science,” to justify actions such as passing new regulations. It is not yet clear whether Pruitt will attempt to use … Continue Reading

Court Upholds Unlimited Look Back Period for OSHA Repeat Violations

By Megan Baroni on March 8, 2018 Posted in OSHA Compliance

The Occupational Safety and Health Act provides for increased penalties when an employer repeatedly violates a standard. While there is no specific time frame established in the statute for how long OSHA can look back for a repeat violation, OSHA guidance and policy documents generally state that the agency will classify a violation as repeated … Continue Reading

EPA to Defer to States on Enforcement

By Megan Baroni on February 8, 2018 Posted in Environmental Compliance & Permitting, Environmental Enforcement

In our 2018 outlook, we told you about the trend towards cooperative federalism—EPA’s plan to “rebalance the power between Washington and the states to create tangible environmental results for the American people.” Early in 2018, EPA has already taken steps towards putting cooperative federalism into practice. At the end of January, EPA Assistant Administrator for the … Continue Reading

2018 Environmental, Health, and Safety Outlook for Manufacturers

By Megan Baroni on January 12, 2018 Posted in Environment, Environmental Compliance & Permitting, Environmental Enforcement, Health & Safety, OSHA Compliance

I want to begin by celebrating the fifth anniversary of our Manufacturing Law Blog. We are passionate about providing you with legal updates that are relevant to your manufacturing business and are honored that you are here. With over 20,000 visits over the course of our blog’s relatively short life, we are proud of the … Continue Reading

The Rise of Vapor Intrusion

By Megan Baroni on October 5, 2017 Posted in Environment, Environmental Compliance & Permitting, Environmental Enforcement

Thank you to my colleague Jim Ray for his contributions to this post. Jim is a partner in our Environmental & Energy Practice Group. We have all been involved in investigating and remediating sites with soil and groundwater contamination. But another form of contamination has been recently gaining attention—vapor intrusion. Vapor intrusion is the migration … Continue Reading

Superfund Reform May Be a Slow Go

By Megan Baroni on September 8, 2017 Posted in Environmental Enforcement

As we previously reported, the current administration set out to make Superfund reform a priority. Shortly after taking over as EPA Administrator, Scott Pruitt convened a task force to provide recommendations for restructuring and streamlining the Superfund cleanup process. Over the summer, Administrator Pruitt endorsed 42 recommendations from the task force. The recommendations included, among … Continue Reading

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

By Megan Baroni on July 27, 2017 Posted in Chemical Regulation, Environmental Compliance & Permitting

Thank you to my colleague, Emilee Mooney Scott, for this post. Emilee is an associate in our Environmental & Utilities Practice Group. 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 … Continue Reading

Superfund Changes Afoot

By Megan Baroni on June 15, 2017 Posted in Environmental Compliance & Permitting

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 a couple of initiatives in an effort to streamline and improve the Superfund process and cleanups. In addition, … Continue Reading

“Take-Home Toxins” Expand Duty of Care Imposed on Employers

By Megan Baroni on April 13, 2017 Posted in Litigation

Thank you to my colleague, Diana Neeves, for this post. Diana is an associate in our Environmental & Utilities Practice Group. A federal district court in Pennsylvania recently found that Accuratus Corporation (“Accuratus”), a ceramics manufacturer and supplier, could be liable under New Jersey law for chemical exposure injuries to the girlfriend and roommate of … Continue Reading

Top 10 OSHA Violations of 2016

By Megan Baroni on March 9, 2017 Posted in OSHA Compliance

Every year, OSHA releases a list of the 10 most frequently cited violations, which, for 2016, were accumulated by reviewing the nearly 32,000 workplace inspections conducted by OSHA staff. The list for 2016 looks a whole lot like the list for 2015 and the preceding years. As OSHA notes, “it rarely changes.” The top 10 … Continue Reading

Lawsuit Proceeds Against Monsanto for Manufacture of PCBs

By Megan Baroni on February 10, 2017 Posted in Environment, Litigation

Last year, we told you about a lawsuit brought by three California cities against Monsanto Company, alleging that Monsanto is liable for PCB (polychlorinated biphenyl) contamination in San Francisco Bay. The cities—San Jose, Berkeley, and Oakland—sued Monsanto for allegedly creating a public nuisance not by discharging PCBs, but just by manufacturing them. In September 2016, … Continue Reading

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