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EPA's Reconsideration of Ethylene Oxide Under the Clean Air Act - A Sign of Future Chemicals Policy to Come?

On January 25, 2022, the U.S. Environmental Protection Agency (“EPA”) reaffirmed its interpretation of ethylene oxide (“EtO”) requirements which may signal EPA’s increased scrutiny of chemical emissions generally and the...more

Major TCEQ Rulemaking Impacts Industrial Companies in Texas

On November 23, 2021, Texas Commission on Environmental Quality (TCEQ) Director of the Office of Compliance requested that TCEQ approve a proposed rulemaking intended to respond to a series of industrial events occurring over...more

EPA’s PFAS Strategic Roadmap Sets Broad and Ambitious Goals

Near- and Longer-Term Objectives Expected to Impact Wide Range of Industries - On October 18, 2021, the Environmental Protection Agency (EPA) released its PFAS Strategic Roadmap: EPA’s Commitments to Action 2021-2024. For...more

California Proposes Designating PFOA as a Carcinogen under Proposition 65

Designation of PFOA as a Carcinogen Will Increase Litigation Risks and Expand Proposition 65 Labeling Obligations - On March 19, 2021, California’s Office of Environmental Health Hazard Assessment (OEHHA) announced that...more

EPA’s Revised Rule for Ethylene Oxide ("EtO") Manufacturers

In a just-released air toxics rule for miscellaneous organic chemical manufacturing (“MON”) sources, the U.S. Environmental Protection Agency (“EPA”) retains its controversial risk value for ethylene oxide (“EtO”). In doing...more

Emerging Regulation, Enforcement, and Litigation Involving Ethylene Oxide, a Critical Substance for Sterilizing Medical Products...

Ethylene oxide (“EtO”), one of the most widely used and effective substances for sterilizing medical products and devices, has come under intense scrutiny by the Environmental Protection Agency (“EPA”), the Food and Drug...more

EPA Announces First-Ever Comprehensive Nationwide PFAS Action Plan

On February 14, 2019, the United States Environmental Protection Agency (“EPA”) published its long-awaited “action plan” intended to address potential risks posed by Per- and Polyfluoroalkyl substances (“PFAS”). PFAS are a...more

A Closer Look At EPA Inspector General's New Strategic Plan

On Oct. 4, the U.S. Environmental Protection Agency's Office of Inspector General released its strategic plan for 2019 to 2023. The OIG is charged with the prevention of fraud, waste, abuse, mismanagement and misconduct in...more

Energy Newsletter - June 2018

Lessons for Sellers in Contracting with Emerging Market Buyers: The “Three R’s” to Structuring Payment Security Provisions - The recent rebound in the international energy industry is being driven, at least in part, by a...more

BSEE Proposes Revisions to 2016 Well Control Rule; Public Comment Period Open Until Early July

On May 11, 2018, the Bureau of Safety and Environmental Enforcement (BSEE) announced proposed revisions to the Oil and Gas and Sulfur Operations in the Outer Continental Shelf ? Blowout Preventer Systems and Well Control Rule...more

BSEE Proposes Revisions to 2016 Well Control Rule

Public Comment Period Open Until Early July - On May 11, 2018, the Bureau of Safety and Environmental Enforcement (BSEE) announced proposed revisions to the Oil and Gas and Sulfur Operations in the Outer Continental Shelf...more

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