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PFOA and PFOS Are CERCLA Hazardous Substances – Now What?

EPA recently issued its long-awaited rule designating perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) as hazardous substances under the Comprehensive Environmental Response, Compensation and Liability...more

2024 Environmental, Health, and Safety Outlook for Manufacturers

PFAS — perfluoroalkyl and polyfluoroalkyl substances — have been on the scene for years now, but we expect to see exponential growth in all things PFAS in 2024....more

California Bans the Manufacture and Sale of Certain PFAS-Containing Products

The State of California has always been a leader in regulating chemical ingredients contained in products sold in the state (think Prop 65), and it has turned its sights towards per- and polyfluoroalkyl substances (PFAS)....more

EPA Establishes New Health Advisories for PFAS

Earlier this month, EPA set new lifetime health advisories for four per- and poly-fluoroalkyl substances (PFAS) – in some instances at levels lower than those that can be detected through laboratory testing. The new health...more

PFAS Update: EPA Progress Under PFAS Action Plan

Earlier this year, we wrote about EPA’s PFAS Action Plan, the agency’s blueprint for addressing contamination and protecting public health from per- and polyfluoroalkyl substances (PFAS). ...more

Environmental Considerations in Corporate Transactions

My partner Bob Melvin and I recently gave a presentation on environmental, health, and safety considerations in mergers and acquisitions. While it would be impossible to cover our entire presentation in a blog post, I thought...more

EPA Unveils PFAS Action Plan

On Valentine’s Day, EPA showed a little love for per- and polyfluoroalkyl substances (PFAS), announcing a sweeping plan to address PFAS contamination and protect public health. ...more

EPA Lists First Sites to NPL for Vapor Intrusion

Last week, EPA added two sites to the National Priorities List (NPL), a list of sites of national priority for known or threatened releases of hazardous substances, solely for the risks posed by vapor intrusion. ...more

Superfund Reform May Be a Slow Go

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...more

Superfund Changes Afoot

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...more

Court Dismisses Public Nuisance Claims Against Monsanto for Manufacture of PCBs

Last week, a federal court dismissed claims brought by three California cities against Monsanto that were aimed at forcing Monsanto to pay for polychlorinated biphenyl (“PCB”) contamination in San Francisco Bay. The...more

Can Air Emissions Lead to CERCLA Liability?

The Comprehensive Environmental Response, Compensation, and Liability Act, 42 U.S.C. § 9601 et seq. (“CERCLA”) imposes fairly broad liability on potentially responsible parties (“PRPs”) to pay for the investigation and...more

Major Expansion of EPA Rules for Underground Storage Tanks

On July 15, 2015, the United States Environmental Protection Agency (EPA) published a final rule significantly expanding its program for underground storage tank (UST) systems that store petroleum or hazardous substances....more

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