Inventory Reset reporting under the Toxic Substances Control Act (TSCA) seems like years ago, because it was – Form A’s were due February 7, 2018 for manufacturers and October 5, 2018 for processors. Companies are now likely...more
Companies that may need to disclose environmental penalties and other environmental information to the Securities and Exchange Commission (SEC) should take note: The disclosure rules are changing. Late last month the SEC...more
Five and a half years after proposing changes to its significant new use rules (SNURs) on per- and polyfluoroalkyl substances (PFAS), EPA has finally released a final rule. On June 22, 2020, EPA issued (in prepublication...more
Key Takeaways:
• What Happened: FDA updated its temporary hand sanitizer production policies to permit use of fuel- or technical-grade ethanol that contains certain impurities up to given limits.
• Who’s Impacted:...more
Key Points:
• OSHA updated its guidance on inspections related to COVID-19 and on recordkeeping for COVID-19 cases on May 19.
• OSHA has extensive guidance on other aspects of protecting employees from the novel...more
Chemical manufacturers and importers may now begin preparation of their 2020 TSCA Chemical Data Reporting (CDR) submissions in earnest. In two separate pre-publication Federal Register notices, EPA has finalized its 2020 CDR...more
Key Takeaways:
• What Happened: FDA announced temporary relief from certain premarket regulatory requirements pertaining to certain new or modified medical devices intended for use against the novel coronavirus....more
In one action, EPA has solved the problem faced by thousands of companies as they prepare to comply with the Toxic Substances Control Act (TSCA) fees rule self-notification requirement. On March 25, 2020, EPA release a...more
During Inventory Reset in 2017-2018, did your company assert on Form A confidentiality claims for chemical identities on the confidential Toxic Substances Control Act (TSCA) Inventory? If so, you risk having EPA make those...more
Beware of fraudulent claims that products will kill the coronavirus (officially, the Novel Coronavirus SARS-CoV-2) or cure the disease caused by that virus (Novel Coronavirus Disease 2019, abbreviated as COVID-19). The Food...more
As the number of novel coronavirus (COVID-19) illness cases continue to grow in the United States, employers should be aware of their legal obligations under the Occupational Safety and Health Act of 1970 (“OSH Act”) and key...more
If your facility has a significant accidental release of a hazardous chemical, your team will need to respond immediately, particularly if the release threatens the public, workers, or the environment. But don’t forget to...more
Who is subject to the upcoming obligation to self-identify as a manufacturer of a high-priority substance and pay a portion of a fee of more than a million dollars under EPA’s Toxic Substances Control Act (TSCA) fees rule? ...more
With the enactment of the PFAS Act of 2019 and related provisions in December, opposing forces in Congress came together to force regulatory action on several different aspects of per- and poly-fluorinated substances (PFAS)....more
California’s Occupational Safety and Health Standards Board adopted a new safety rule on January 16, 2020, requiring employers to provide employees with access to their written Injury and Illness Prevention Plan (IIPP) within...more
Companies now have more guidance on how to communicate Proposition 65 warnings for products sold through distributors. The California Office of Environmental Health Hazard Assessment (OEHHA) finalized the amendments proposed...more
The chemical 1,4-dioxane has become a hot topic for EPA and state regulators. New York recently adopted a law banning more than trace amounts of the chemical in cosmetics, personal care products, and cleaning products....more
A centerpiece of EPA’s PFAS Action Plan, issued in February 2019, is finalizing a 2015 proposed rule under the Toxic Substances Control Act (TSCA) that would amend two significant new use rules (SNURs) on some 500...more
The California Department of Toxic Substances Control (DTSC) is moving forward with a process that may ultimately impose restrictions on the use of certain classes of chemicals in food packaging products under the Safer...more
EPA has taken another step toward implementing its PFAS Action Plan by publishing an Advanced Notice of Proposed Rulemaking (ANPR) on December 4, 2019, 84 Fed. Reg. 66369. The ANPR solicits comments on whether per- and...more
Nearly three years after adopting extensive amendments to its rules on accidental release prevention under the Clean Air Act, the Environmental Protection Agency (EPA) adopted a final rule rescinding nearly all of the...more
By January 1, 2020, the California Cleaning Product Right to Know Act (California RTK Act) will require manufacturers of certain covered cleaning products to make extensive ingredient disclosures on their company websites. By...more
For employers wishing to train employees using computer-based, online programs, OSHA recently reiterated that safety and health training must still include interactive and hands-on opportunities for employees. This may...more
Beginning this month, OSHA will be using a new system to weigh and measure enforcement activity in order for the Agency to (1) more accurately allocate resources required to perform enforcement related activities, and (2)...more
For the first time in over 30 years, the Securities and Exchange Commission (SEC) has proposed amendments to modernize its regulation requiring registrants to report environmental penalties and certain other environmental...more