Pamela Elkow

I’m a partner in Robinson+Cole’s Environmental and Utilities Practice Group. I’ve been practicing law with a focus on environmental and health and safety issues for over 20 years. I work with a wide variety of clients, ranging from Fortune 50 companies and large institutions such as universities, to small, closely-held businesses and municipalities. Here’s the link to my full and official bio.

Many of my clients are manufacturers with ongoing environmental, health and safety issues associated with their business operations. I advise them on day-to-day compliance and permitting issues, work with them to compile or review health and safety manuals, and defend them against enforcement actions resulting from allegations of violations of environmental or occupational health and safety regulations. I see myself as part of the client team – my task is not just to raise issues and liabilities, but to work with the client to come up with cost-effective, practical solutions to those issues, and to minimize liabilities. To do that, I need to know the business – what do they make and how do they make it? I’m comfortable talking to management, or the folks on the floor. Getting to know the business and how the client does what they do – that’s what drives me to work with manufacturers. I’m never happier than when learning how something works, how something is made, or just something new.

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Transitioning to Safer Chemicals – A Win, Win, Win….

Last week, we discussed the new OSHA “Annotated Permissible Exposure Limits,” which OSHA announced in a press release dated Thursday, Oct. 24.  In the same press release, OSHA announced its new “Safer Chemical Tool Kit” for employers. The idea is to go beyond compliance, and substitute, reduce, or even eliminate chemical hazards.  This is not a … Continue Reading

OSHA to Industry – “Our PELs May Not be ‘Safe Enough’.”

In a press release dated Thursday, Oct. 24,  OSHA let industry know that it was issuing guidance for employers in the form of “Annotated Permissible Exposure Limits.”  Recognizing that its published Permissible Exposure Limits or PELs (i.e., the concentrations of chemicals to which an employee can be safely exposed during a work shift) are often … Continue Reading

What’s your on-line (EHS) profile?

Did you know…. your compliance history (and other information about your company or your site) is readily available on USEPA and OSHA’s websites, as well as many state environmental agency websites. Envirofacts, at EPA, has the most information.  Someone can search the “Multisystem”  database, or by various topic searches: air, waste, facility, land, toxics, compliance, … Continue Reading

In Case You Missed It – What’s New at EPA

The Manufacturing Law Blog provides timely commentary on issues of importance to manufacturers and distributors.  Contributors from the law firm of Robinson & Cole LLP are corporate compliance and litigation attorney, Jeff White; environmental, health and safety attorney, Pam Elkow;  and labor and employment attorney, Nicole Bernabo. It’s summer, and it’s easy to get behind on reading, … Continue Reading

Gina McCarthy – the New EPA Administrator

The Manufacturing Law Blog provides timely commentary on issues of importance to manufacturers and distributors.  Contributors from the law firm of Robinson & Cole LLP are corporate compliance and litigation attorney, Jeff White; environmental, health and safety attorney, Pam Elkow;  and labor and employment attorney, Nicole Bernabo. Here’s a (pretty) short summary on the new EPA Administrator, … Continue Reading

Keeping C-PACE – Financing for Clean Energy Improvements

The Manufacturing Law Blog provides timely commentary on issues of importance to manufacturers and distributors.  Contributors from the law firm of Robinson & Cole LLP are corporate compliance and litigation attorney, Jeff White; environmental, health and safety attorney, Pam Elkow;  and labor and employment attorney, Nicole Bernabo While this blog focuses on manufacturers, many of you are … Continue Reading

Mushrooming Retaliation and Whistleblower Claims

 * The Manufacturing Law Blog provides timely commentary on issues of importance to manufacturers and distributors.  Contributors from the law firm of Robinson & Cole LLP are corporate compliance and litigation attorney, Jeff White; environmental, health and safety attorney, Pam Elkow;  and labor and employment attorney, Nicole Bernabo.  One of the goals of the Manufacturing Log Blog … Continue Reading

Are You Buying or Selling? Environmental Due Diligence in a Stock Sale

 * The Manufacturing Law Blog provides timely commentary on issues of importance to manufacturers and distributors.  Contributors from the law firm of Robinson & Cole LLP are corporate compliance and litigation attorney, Jeff White ; environmental, health and safety attorney, Pam Elkow;  and labor and employment attorney, Nicole Bernabo.  Way back when, before the world as we know … Continue Reading

A Waste to Energy Success Story

* The Manufacturing Law Blog provides timely commentary on issues of importance to manufacturers and distributors.  Contributors from the law firm of Robinson & Cole LLP are corporate compliance and litigation attorney, Jeff White; environmental, health and safety attorney, Pam Elkow; and labor and employment attorney, Nicole Bernabo.  A Waste to Energy Success Story  My posts … Continue Reading

Blowing the Whistle on Yourself – NYSDEC Proposes Environmental Audit Incentive Policy

Most States, including New York, Connecticut and Massachusetts, and the US EPA have “audit policies”, which are really self-reporting policies, promising small or no fines if a company self-reports a violation that does not otherwise require reporting.  The New York State Department of Environmental Conservation is now proposing a policy to encourage companies to do … Continue Reading

The Emergency Planning and Community Right-to-Know Act – Do you know your obligations? Part 1 – Storage Reporting Requirements

Pop quiz: What’s a hazardous chemical? What’s an extremely hazardous substance (EHS)? And what’s a threshold planning quantity (TPQ)? In 2012, did you store at your facility more than 10,000 pounds of a hazardous chemical, or more than 500 pounds of an EHS? Or an EHS in exceedance of the TPQ? Have you provided copies … Continue Reading

Document that Health and Safety Training

With enough to worry about when it comes to employee safety, what you should not be worrying about is getting cited for violations you didn’t commit. Unfortunately, in the OSHA realm, that has happened just because someone wasn’t keeping very good records. This is particularly true when it comes to training. OSHA standards require a … Continue Reading
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