On October 12, 2022, the Office of Environmental Justice and External Civil Rights of the U.S. Environmental Protection Agency (EPA) issued a Letter of Concern setting forth its initial analysis and recommendations in...more
On September 21, 2022, Michael Bloomberg announced his newest grassroots public health and climate change campaign called Beyond Petrochemicals: People over Pollution. Still in its early conceptual stages, the campaign will...more
The U.S. Environmental Protection Agency’s (EPA) commitment to its controversial Integrated Risk Information System (IRIS) value for Ethylene Oxide (EO) remains unwavering as two recent developments reflect. The first is...more
What?
The U.S. Environmental Protection Agency (EPA) has announced that it is conducting helicopter flyovers of oil and gas operations in the Permian Basin to identify and pursue enforcement for unauthorized emissions of...more
Key Takeaways -
• Ethylene Oxide (EO) remains a high priority for the Biden Environmental Protection Agency (EPA) from both a risk and an environmental justice standpoint. Expect that spotlight to continue next year and...more
On November 2, 2021, President Biden released the U.S. Methane Emissions Reduction Action Plan (the “Plan”). The Plan, calling for substantial reductions in U.S. methane emissions, was announced in tandem with an...more
Overview and Potential Action for Industry Stakeholders -
On October 1, 2021, the Environmental Protection Agency (EPA or Agency) issued for public comment its Draft Strategic Plan to Address Climate Change and Advance...more
On May 20, 2021, President Biden issued his Executive Order on Climate-Related Financial Risk, stating that it is the policy of the Administration to “advance consistent, clear, intelligible, comparable, and accurate...more
The Texas Commission on Environmental Quality (TCEQ) has taken various actions and posted guidance to help regulated entities address operational issues and environmental noncompliance that resulted from power outages, water...more
Key Takeaways What: In late January, EPA took the initial step of posting status reports on 25 facilities previously identified as high-risk based on known ethylene oxide (EO) emissions and facility location. EPA has...more
Key Takeaways What:
On January 4, 2021, EPA determined that community-specific warnings regarding ethylene oxide (EO) risks need not be made immediately. EPA has now committed to making notifications by May 31, 2021 and...more
Key Takeaways:
• What: The Texas Commission on Environmental Quality (TCEQ) has revised its policy on calculating monetary penalties for administrative enforcement actions.
• Who Is Affected: Entities with...more
It’s no secret that President Biden plans to prioritize action on climate change. During his presidential campaign, Biden identified climate change as one of his top four priorities, and announced he would seek to put the...more
Key Takeaways -
• What: The U.S. Environmental Protection Agency (EPA)’s scientific work on ethylene oxide (EO) has been central to the basis of claims in recent toxic tort suits based on EO exposures; the Biden...more
Key Takeaways:
What: The Texas Commission on Environmental Quality (TCEQ) has developed a “Find It and Fix It” program for oil and gas facility air compliance....more
Comments are due November 19, 2020, on a proposed revision to Brazil’s technical standard on chemical labeling and hazard communications, NBR 14725: “Information on Health, Safety, and Environment – General Aspects of the...more
Key Takeaways -
• What Happened: TCEQ issues draft Penalty Policy and plans to propose Compliance History Rule revisions...
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Key Takeaways -
• What Happened: EPA urges self-audits for facilities subject to RCRA Parts 264/265 Subparts AA, BB and CC air emission standards to avoid potential for substantial penalties and injunctive relief
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Key Takeaways -
• What Happened: EPA finalized new procedures for issuing, identifying, and maintaining Agency guidance documents....more
If Joe Biden is elected President, and the Democrats win control of both the House and Senate, the new Administration could potentially use the Congressional Review Act (“CRA” or “Act”) to reverse recent and still-to-come...more
On August 12, the United States Environmental Protection Agency (EPA) published the final “residual risk and technology” (RTR) rule for the Miscellaneous Organic Chemical Manufacturing (MON) source category (Final Rule or MON...more
Late last week four Colombian agencies—including the ministries of health (Ministerio de Salud y Protección Social), labor (Ministerio del Trabajo), commerce (Ministerio de Comercio, Industria y Turismo), and the environment...more
On August 31, the U.S. Environmental Protection Agency (EPA) will terminate its March 26, 2020 policy that provided enforcement discretion for certain types of violations due to impacts from COVID-19. The policy identified...more
EPA has recently confirmed that it is reviewing its March 26, 2020 guidance that provided enforcement discretion for certain types of violations due to impacts from COVID-19. The policy, described in a prior Beveridge and...more
On March 26, 2020, EPA issued new guidance addressing a range of issues relating to environmental compliance and enforcement during the COVID-19 pandemic. The Agency sets expectations for the regulated community to continue...more