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The Future Is Now for TSCA Risk Management Rulemaking for Asbestos and Other Chemicals

EPA has proposed a ban on the ongoing uses of chrysotile asbestos, illustrating EPA’s strong authority under section 6 of the Toxic Substances Control Act (TSCA). Nevertheless, it is the alternatives to a ban that EPA...more

What’s Next for OSHA Rulemaking on COVID-19 and Other Infectious Diseases

OSHA has officially withdrawn its COVID-19 vaccination and testing emergency temporary standard (ETS), 29 C.F.R. § 1910.501, per a notice in the January 26 Federal Register. 87 Fed. Reg. 3928 (Jan. 26, 2022). As explained in...more

After the Supreme Court Decision, What Comes Next for OSHA and COVID-19

The Supreme Court has put on hold the OSHA emergency temporary standard (ETS) on COVID-19 vaccination and testing. This stay will mean that OSHA probably cannot enforce the ETS prior to its expected expiration in May. OSHA...more

TSCA in 2022: Fasten Your Seatbelt

A year into the Biden Administration’s implementation of the 2016 amendments of the Toxic Substances Control Act (TSCA), EPA is planning an ambitious suite of actions under sections 4, 5, 6, 8, 14, and 23. Companies and trade...more

Rapid Developments for OSHA’s COVID-19 Emergency Temporary Standards

One in, one out, one in again. One in: Employers with 100 employees or more should be prepared to comply with OSHA’s emergency temporary standard (ETS) that would require them to have their employees fully vaccinated or...more

Importers of Mercury-Containing Articles Face Reporting Requirements

More than four years after finalizing reporting requirements for the manufacture, import, export, processing, and distribution in commerce of elemental mercury and mercury-added products, EPA has eliminated an exemption for...more

New OSHA ETS Requires Two-Thirds of Private Employers to Mandate COVID-19 Vaccination or Require Regular Testing

The U.S. Occupational Safety and Health Administration (OSHA) has issued a new emergency temporary standard (ETS) that requires employers with 100 or more employees to mandate that all employees be vaccinated against COVID-19...more

EPA Proposes to Extend Key PIP (3:1) Rule Compliance Deadline to October 31, 2024 (Updated)

Following up on the short-term extension that it issued in September, EPA has issued a notice of proposed rulemaking that will further extend the compliance deadline for the processing and distribution in commerce of certain...more

EPA Proposes to Extend Key PIP (3:1) Rule Compliance Deadline to October 31, 2024

October 26, 2021 Update: Following up on the short-term extension that it issued in September, EPA has issued a notice of proposed rulemaking that will further extend the compliance deadline for the processing and...more

New TSCA Section 8(d) Rule Adds 50 Chemicals to Reporting Requirements (Updated)

EPA has issued a prepublication version of a final rule to extend the submission deadline for the TSCA Health and Safety Data Reporting rule to December 1, 2021 for the 20 High Priority Substances, and to January 25, 2022 for...more

EPA Will Not Enforce Key PIP (3:1) Rule Compliance Deadline Until 2022

Updated September 17, 2021: EPA continues to extend a key compliance deadline for PIP (3:1). In a final rule effective September 17, 2021, EPA delayed enforcing compliance with the ban on processing and distributing PIP...more

Prepare Now for a New OSHA Emergency Temporary Standard on COVID-19

Employers with 100 or more employees should expect a new emergency temporary standard (ETS) from the Occupational Safety and Health Administration (OSHA) requiring them to mandate that all employees be vaccinated against...more

Protecting Unvaccinated and Otherwise At-Risk Workers in Workplaces Not Covered by OSHA’s COVID-19 Emergency Temporary Standard...

OSHA has updated its guidance on workplace protections for unvaccinated and otherwise at-risk workers who are not covered by the COVID-19 Emergency Temporary Standard (ETS) for Healthcare. The updated guidance, issued August...more

OSHA Issues Updated Guidance on COVID-19 Enforcement

Key Takeaways: • On July 7, 2021, OSHA issued revisions to its National Emphasis Program for COVID-19, DIR 2021-03 (CPL 03) (“Revised COVID-19 NEP”), and released an Updated Interim Enforcement Response Plan for...more

New TSCA Section 8(d) Rule Adds 50 Chemicals to Reporting Requirements

Section 8(d) of the Toxic Substances Control Act (TSCA) had been effectively a dead provision of TSCA for over a decade. EPA has just revived it by adopting an immediate final rule mandating the submission of health and...more

Article Importers May Face Another TSCA Obligation, This One Related to PFAS

Do any of the articles, or article components, that your company imports contain PFAS? If so, your company may become subject to extensive reporting requirements proposed by EPA under the Toxic Substances Control Act (TSCA)....more

After Several Rounds of Revisions, Updated Cal/OSHA COVID-19 Emergency Temporary Standards Take Effect

Over the last two months, the California Occupational Safety & Health Standards Board (“Board”) has considered several versions of proposed updates to the emergency temporary COVID-19 standards that were first adopted in...more

Vermont Enacts Restrictions on PFAS Chemicals

Vermont now has a law restricting per- and polyfluoroalkyl substances (PFAS) in a variety of products. After unanimous approval by both houses of the Vermont legislature, Governor Phil Scott signed into law S.20, an act that...more

OSHA Issues a COVID-19 Emergency Temporary Standard for Healthcare and Guidance for General Industry

After much anticipation and debate, the Occupational Safety and Health Administration (OSHA) issued an emergency temporary standard (ETS), contained in 29 C.F.R. Part 1910, Subpart U, on June 10, 2021, but solely for...more

OSHA to Update Hazard Communication Standard

OSHA’s hazard communication standard (HCS) is the principal federal requirement governing labels and safety data sheets (SDSs) for hazardous chemicals used in the workplace in the United States. OSHA has proposed to update...more

New OSHA Guidance for COVID-19 Prevention Programs

On January 29, 2021, OSHA released new COVID-19 guidance in accordance with the January 21, 2021 Executive Order on Protecting Worker Health and Safety. The new guidance, entitled “Protecting Workers: Guidance on Mitigating...more

EPA Ordered to Revise TSCA CDR Rule for Asbestos

A federal court has ordered EPA to make extensive changes to its Chemical Data Reporting rule (CDR) with respect to asbestos reporting. While the ruling in ADAO v. Wheeler is limited to CDR reporting of asbestos, it sets the...more

Michigan Adopts Emergency Temporary Standard on COVID-19

Michigan’s emergency COVID-19 worker safety rules took effect on October 14, 2020. The rules apply to all employers covered under Michigan’s occupational safety and health act. The Michigan Occupational Safety and Health...more

Oregon Adopts a Temporary Standard for COVID-19

Oregon has joined Michigan and Virginia in adopting an emergency temporary rule for COVID-19. On November 6, 2020, Oregon Occupational Safety & Health (Oregon OSHA), a division of the Department of Consumer & Business...more

Tenth Circuit Upholds OSHA Interpretations on Scope of PSM Standard

On October 27, 2020, the Tenth Circuit upheld a series of OSHA citations that were issued to an oil refining company following a fatal boiler explosion. In doing so, the Tenth Circuit upheld OSHA interpretations that...more

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