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…
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…
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,…
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,…
Special thanks to my colleague, Brian C. Freeman, for this post. Brian is an attorney in our Environmental & Utilities group with a particular focus on air quality.
Refrigeration and cooling systems face expanded and tighter regulation under a final rule recently signed by EPA Administrator Gina McCarthy. The rule revises and expands EPA’s…
To round out our series on industry and legal outlooks for 2016, I have compiled some of the many things for manufacturers to be aware of in the Environmental Health & Safety world for 2016.
1. Expansion of CERCLA Liability
The Comprehensive Environmental Response, Compensation, and Liability Act (“CERCLA”) is always a concern for manufacturers…
EPA is poised to publish a proposed rule revising regulations applicable to hazardous waste generators under the Resource Conservation and Recovery Act, 42 U.S.C. § 6901 et seq. (RCRA). The proposed rule, which has not yet been published in the Federal Register, represents a significant overhaul of the RCRA generator regulations. EPA states that…
EPA is in the process of rolling out Next Generation Compliance, or NextGen, in an effort to make its programs more effective, facilitate compliance, and, ultimately, enhance environmental benefit. But in many ways, NextGen seems poised to expand enforcement against the regulated community.
NextGen consists of five interconnected components:
…
Thank you to my colleague Brian Freeman for his contributions to this post. Brian is an attorney in the Environmental & Utilities Practice Group who has significant experience with underground storage tank issues for industrial and petroleum clients.
On July 15, 2015, the United States Environmental Protection Agency (EPA) published a final rule significantly expanding…
Thank you to my colleague Bob Melvin for his contributions to the post below. Bob is a partner in the Environmental & Utilities Practice Group whose practice focuses on representing manufacturers with enforcement, compliance, and permitting issues.
Under EPA’s Audit Policy and Small Business Compliance Policy, companies that discover, promptly disclose, and expeditiously correct…
