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TSCA Implementation Update: EPA Releases Updated Inventory and Delays Risk Evaluations

As we previously outlined, the Toxic Substances Control Act (“TSCA”) was amended in 2016 to provide EPA with much broader authority to regulate “existing” chemical substances (i.e., those that are already in use in commerce)....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

2019 Environmental, Health, and Safety Outlook For Manufacturers

This is the last of our three-part series of predictions for 2019. First Matt provided our thoughts and predictions in the labor/employment arena. Last week, Jeff gave our outlook for corporate compliance and litigation. ...more

Data Privacy + Cybersecurity Insider - December 2018 #2

A report released by cybersecurity firm Agari has come to conclusion that we have been experiencing all year—a hacking group in Nigeria, dubbed “London Blue,” is targeting CFOs and controllers from small businesses to...more

OSHA’s Use of Drones During Workplace Inspections

These days, it is not uncommon to see drones flying overhead. But employers beware…you might see one during your next workplace inspection....more

OSHA Clarifies Position On Anti-Retaliation Rule

As all members of the construction industry know, the prevention of the occurrence of work-related injuries and illnesses is a constant concern, and one that can have serious implications for the various contractual...more

OSHA Clarifies Position On Anti-Retaliation Rule

Thank you to Jonathan Schaefer for this post. Jon is an attorney in our Environmental, Energy & Telecommunications Practice Group and his practice focuses on environmental compliance counseling, occupational health and...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

Monsanto Verdict Forewarns of Claims for Failure to Warn

By now, we have all heard about the $289 million verdict against Monsanto in the Roundup litigation. A California jury awarded the sum to Dewayne “Lee” Johnson, a school groundskeeper who claimed that exposure to Roundup...more

Climate Change Nuisance Lawsuit Dismissed

This week, a California federal court dismissed a lawsuit brought by two cities against a number of large oil companies seeking to force the companies to fund the cities’ climate change adaptation efforts. The Court held...more

EPA to Rethink Cost-Benefit Analyses During Rulemaking Process

This week, EPA announced that it is considering developing regulations to optimize the use of cost-benefit analyses when it is taking regulatory action. Many environmental statutes require the consideration of costs and...more

Failed to File An Electronic Injury Report? OSHA May Be Looking For You

Under the 2016 Recording and Reporting Occupational Injuries and Illnesses rule (RROII Rule), December 30, 2017 was the first deadline for certain employers to electronically submit their 2016 300A summary forms, which...more

EPA Considering Ban On The Use Of Private Scientific Data

EPA Administrator Scott Pruitt is considering a plan to restrict the agency’s use of scientific data to only that data which is publicly available. The move would prevent EPA from using private studies, dubbed “secret...more

Court Upholds Unlimited Look Back Period for OSHA Repeat Violations

The Occupational Safety and Health Act provides for increased penalties when an employer repeatedly violates a standard. While there is no specific time frame established in the statute for how long OSHA can look back for a...more

Environmental Enforcement Actions Could be Curtailed by New DOJ Policy

In a shift of federal policy with potentially sweeping implications for civil enforcement, the U.S. Department of Justice (DOJ) recently announced it will no longer rely on guidance documents as the basis for bringing...more

EPA to Defer to States on Enforcement

In our 2018 outlook, we told you about the trend towards cooperative federalism—EPA’s plan to “rebalance the power between Washington and the states to create tangible environmental results for the American people.” Early in...more

2018 Environmental, Health, and Safety Outlook for Manufacturers

Reduced Regulation - We all know that one of President Trump’s goals is to streamline and minimize regulations. Among other things, Executive Order 13771 indicated that, for every regulation to be passed, two had to be...more

OSHA: Disclosure of Workplace Injuries and Illnesses Due Next Week

As we outlined last year, OSHA recently revised its recording and reporting regulation to require certain employers to submit injury and illness data to OSHA on an annual basis for posting on OSHA’s website. The deadline for...more

The Rise of Vapor Intrusion

We have all been involved in investigating and remediating sites with soil and groundwater contamination. But another form of contamination has been recently gaining attention—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

TSCA Implementation Update: EPA Finalizes Framework Rules and Announces Scope For First Risk Evaluations

TSCA Framework Rules Promulgated - As we outlined last year, the Toxic Substances Control Act (“TSCA”) was recently updated to provide EPA with much broader authority to regulate “existing” chemical substances (i.e., those...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

“Take-Home Toxins” Expand Duty of Care Imposed on Employers

A federal district court in Pennsylvania recently found that Accuratus Corporation (“Accuratus”), a ceramics manufacturer and supplier, could be liable under New Jersey law for chemical exposure injuries to the girlfriend and...more

Top 10 OSHA Violations of 2016

Every year, OSHA releases a list of the 10 most frequently cited violations, which, for 2016, were accumulated by reviewing the nearly 32,000 workplace inspections conducted by OSHA staff. The list for 2016 looks a whole lot...more

Lawsuit Proceeds Against Monsanto for Manufacture of PCBs

Last year, we told you about a lawsuit brought by three California cities against Monsanto Company, alleging that Monsanto is liable for PCB (polychlorinated biphenyl) contamination in San Francisco Bay. The cities—San Jose,...more

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