News & Analysis as of

Comment Period Hazardous Substances

Bergeson & Campbell, P.C.

EPA Proposes to Extend Certain Compliance Deadlines to Ensure Lab Compliance with Final Methylene Chloride Risk Management Rule

On May 20, 2025, the U.S. Environmental Protection Agency (EPA) released a proposed rule that would extend certain compliance dates in the final risk management rule for methylene chloride under the Toxic Substances Control...more

Bergeson & Campbell, P.C.

EPA Extends Comment Period on Draft Sewage Sludge Risk Assessment for PFOA and PFOS

On April 17, 2025, the U.S. Environmental Protection Agency (EPA) extended the comment period on a draft risk assessment of the potential human health risks associated with the presence of perfluorooctanoic acid (PFOA) and...more

Faegre Drinker Biddle & Reath LLP

PADEP Publishes Proposed Rulemaking Updating Spill Reporting Requirements

On April 5, 2025, the Pennsylvania Department of Environmental Protection (PADEP) published in the Pennsylvania Bulletin notice of a long-awaited proposed rulemaking that would establish new requirements for reporting spills,...more

Lathrop GPM

EPA Releases Long Awaited Risk Assessment of PFOA and PFOS in Biosolids

Lathrop GPM on

On January 14, 2025, the EPA released for public comment a risk assessment report evaluating the potential risks associated with land application and land disposal of biosolids containing two types of PFAS, PFOA and PFOS....more

Akin Gump Strauss Hauer & Feld LLP

FDA Issues RFI on PFAS in Seafood

On November 19, 2024, FDA issued a request for information (RFI) on per-and polyfluoroalkyl substances (PFAS) in seafood. Specifically, the agency is seeking scientific data and information from the seafood industry and other...more

Kelley Drye & Warren LLP

Minnesota Requests Public Comments by December 19 on Consolidated PFAS Reporting and Fee Rulemaking

Kelley Drye & Warren LLP on

The Minnesota Pollution Control Agency (“MPCA” or ​“the Agency”) is requesting comments by December 19 on development of the state’s program for reporting per- and polyfluoroalkyl substances (“PFAS”) in products and the...more

Bergeson & Campbell, P.C.

EPA Extends Deadline for Public Comment on Manufacture of Certain PFAS during Fluorination of HDPE and Other Plastic Containers

On November 20, 2024, the U.S. Environmental Protection Agency (EPA) announced an extension to the comment period for the notice published September 30, 2024, seeking public comment on the manufacture of certain per- and...more

Holland & Knight LLP

A Little Breathing Room for Product Importers: EPA Extends TSCA 8(a)(7) Reporting Deadline

Holland & Knight LLP on

While product importers were spending the summer poring over the Instructions for Reporting PFAS Under TSCA Section 8(a)(7) (May 2024), the U.S. Environmental Protection Agency (EPA) was working on a Direct Final Rule and...more

BakerHostetler

EPA Takes Next Step Toward New Formaldehyde Regulations

BakerHostetler on

On March 15, 2024, the United States Environmental Protection Agency (EPA) released the draft risk evaluation for formaldehyde for public comment and peer review. The draft risk evaluation was promulgated pursuant to EPA’s...more

Holland & Knight LLP

EPA Proposes RCRA Corrective Action Expansions Targeting PFAS

Holland & Knight LLP on

The 1984 Hazardous and Solid Waste Amendments amended the Resource Conservation and Recovery Act (RCRA) to add the following sections requiring corrective action for releases of hazardous waste or hazardous constituents ...more

Kelley Drye & Warren LLP

EPA Extends RCRA ​“Hazardous Constituents” Proposal to Nine PFAS

On January 31, 2024, the United States Environmental Protection Agency (“EPA” or ​“the Agency”) issued a proposal to amend Resource Conservation and Recovery Act (“RCRA”) regulations to include nine specific per- and...more

Nossaman LLP

Interior Issues New NRDAR Type A Rule for Comment

Nossaman LLP on

On January 5, 2024, the Department of the Interior (Interior) will issue a notice of a proposed rulemaking (NPRM) to provide the first significant revisions to its natural resource damage assessment and restoration (NRDAR)...more

Benesch

Hazmat Modernization Comment Period Approaching

Benesch on

The U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (“PHMSA”) is accepting comments through December 4, 2023 regarding forty-six (46) topics for proposed updates to the Hazardous...more

Robinson+Cole Environmental Law +

Back From the Grave? “Once In, Always In” for Hazardous Air Pollutant Emissions

In the Byzantine complexity of the Clean Air Act (CAA), EPA’s “once in, always in” policy regarding hazardous air pollutants (HAP) has been particularly confounding.  And now it’s back in play, through regulatory revisions...more

Holland & Knight LLP

EPA Seeks Comment on Air Pollutant Reporting for PFAS

Holland & Knight LLP on

The U.S. Environmental Protection Agency (EPA) announced on July 25, 2023, a proposed rule, published in the Federal Register on Aug. 9, 2023, to update the Air Emissions Reporting Requirements (AERR) to collect certain...more

Mitchell, Williams, Selig, Gates & Woodyard,...

PFAS/Advanced Notice of Proposed Rulemaking: ASTSWMO Comments on EPA Query Regarding Additional CERCLA Hazardous Designations

The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) submitted June 15th comments on the United States Environmental Protection Agency’s (“EPA”) Advanced Notice of Proposed Rulemaking...more

Bergeson & Campbell, P.C.

PHMSA Seeks Comment on Initiatives to Modernize the HMR

On July 5, 2023, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published an advance notice of proposed rulemaking (ANPRM) to solicit stakeholder feedback on initiatives PHMSA is considering that may...more

Nelson Mullins Riley & Scarborough LLP

NEWMOA Releases First-of-its-kind PFAS Regional Draft Model Legislation for Public Comment

The Northeast Waste Management Officials’ Association (NEWMOA), a non-profit interstate association composed of members from environmental agencies in seven northeastern states, recently published draft model legislation that...more

Bergeson & Campbell, P.C.

Canada Begins Public Consultation on Draft State of PFAS Report, Proposes to Recommend Adding PFAS to CEPA Schedule 1

On May 20, 2023, Canada published a Canada Gazette notice announcing the availability of its Draft State of Per- and Polyfluoroalkyl Substances (PFAS) Report (Draft Report). Canada proposes to conclude that the class of PFAS...more

Akerman LLP

EPA’s Proposed Rules Would Severely Limit PFAS Levels Permissible in Drinking Water

Akerman LLP on

Last month, the U.S. Environmental Protection Agency (EPA) published new proposed rules under the Safe Drinking Water Act that will severely limit the levels of certain substances of a man-made family of chemicals,...more

BakerHostetler

Overview of Proposed Regulations Superfund Taxes

BakerHostetler on

On March 29, the IRS and U.S. Treasury Department (Treasury) published proposed regulations regarding the recently reinstated Superfund chemical taxes (Proposed Regulations) and set a May 28 deadline for comments. The...more

BCLP

PFAS Update: EPA Issues Advance Notice of Proposed Rulemaking to Designate Seven or Potentially Many More PFAS Compounds As...

BCLP on

EPA has spent the last several years working on listing perfluorooctanoic acid (“PFOA”) and perfluorooctanesulfonic acid (“PFOS”) as Hazardous Substances under the Comprehensive Environmental Response, Compensation, and...more

Vinson & Elkins LLP

Seven More PFAS for Superfund? EPA’s Potential Designation of New Hazardous Substances Under CERCLA

Vinson & Elkins LLP on

The EPA (or “Agency”) is seeking public input and data regarding the potential future designation of seven per- and polyfluoroalkyl substances (“PFAS”) under the Comprehensive Environmental Response, Compensation, and...more

Beveridge & Diamond PC

EPA Seeks Comments on Potential Designation of Additional PFAS as CERCLA Hazardous Substances

Beveridge & Diamond PC on

On April 13, 2023, the U.S. Environmental Protection Agency (EPA) published in the federal register an Advanced Notice of Proposed Rulemaking (ANPRM) seeking public input to inform its decision whether to designate additional...more

Jenner & Block

To Broaden or Not to Broaden--U.S. EPA Solicits Input on Whether to Add Additional PFAS to CERCLA’s List of Hazardous Substances

Jenner & Block on

As we await final agency action on U.S. EPA’s pending rulemaking to designate perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) as CERCLA hazardous substances, U.S. EPA has just published an advanced...more

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