EPA recently issued its long-awaited rule designating perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) as hazardous substances under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). Along with the rule, EPA issued PFAS Enforcement Discretion and Settlement Policy Under CERCLA. This policy document provides the regulated community with some insight as to how
Environmental Enforcement
2024 Environmental, Health, and Safety Outlook for Manufacturers
This week’s post includes an excerpt from our co-authored article “PFAS will be increasing concern for manufacturers in year ahead,” published in the Hartford Business Journal’s Economic Forecast issue on January 8, 2024.
PFAS — perfluoroalkyl and polyfluoroalkyl substances — have been on the scene for years now, but we expect to see…
As the Temperature Rises, Employer Obligations Rise Too
Below is an excerpt of an article co-authored with Environmental, Energy + Telecommunications Group lawyer Jon Schaefer, published by EHS Today on August 31, 2023.
Across the country, manufacturers are learning they need to ensure employees working both inside and out are adequately protected from heat-related risks. Earlier in the summer, OSHA issued the…
EPA Proposes Enforceable Drinking Water Standards For PFAS
This week’s post is authored by Emilee Mooney Scott and is also available on Robinson+Cole’s Environmental Law + blog. Thank you to Emilee for contributing. Emilee is a partner in the firm’s Environmental, Energy + Telecommunications Group, focusing her practice on a variety of environmental compliance and transactional matters, including emerging contaminants.
In mid-March…
EPA Proposes to Designate PFOS and PFOA as CERCLA Hazardous Substances
Thank you to Emilee Mooney Scott for this post. Emilee is a member of Robinson+Cole’s Environment, Energy + Telecommunications practice group. She focuses her practice on environmental compliance, transactional and remediation matters, including matters related to emerging contaminants like PFAS.
Last week, the U.S. Environmental Protection Agency (EPA) released a pre-publication version of a Proposed…
Environmental Justice: An EPA Enforcement Priority
As we reported at the beginning of the year, President Biden has been making environmental justice one of his priorities since long before he took office. The United States Environmental Protection Agency (EPA) recently took a step to add some teeth to the Biden Administration’s commitment to increase environmental enforcement in communities disproportionally impacted by…
Executive Orders Seek to Limit the Bite of Agency Guidance
On October 9, 2019, President Trump issued two executive orders regarding agency guidance – one focused on the development of new guidance and the other on the appropriate use of guidance in enforcement actions. And EPA is not wasting any time taking action. EPA Administrator Andrew Wheeler issued a memorandum on October 21, 2019 announcing…
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…
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…
The End of Conflict Minerals?
We have been talking about conflict minerals for years. And, so have our manufacturing clients. As covered previously in this blog, the conflict minerals laws and regulations are some of the most well known, but least understood laws/regulations that face manufacturers/distributors today.
The stated purpose of conflict mineral laws and regulations were laudable, namely,…