As we have previously reported, PFAS (per- and polyfluoroalkyl substances) are a class of substances coming under increasing regulatory scrutiny. As manufacturers ring in the new year they should be aware of two new PFAS...more
The U.S. Environmental Protection Agency (EPA or Agency) has issued two pre-publication announcements on notable regulatory actions that may affect your business. The first one will increase the amount of information that...more
The U.S. Environmental Protection Agency (U.S. EPA) recently proposed to change annual chemical release reporting requirements for industrial facilities that manufacture, process or otherwise use even very small quantities of...more
Seyfarth Synopsis: On December 20, 2019, the National Defense Authorization Act for Fiscal Year 2020 (NDAA) was signed into law, including provisions for adding certain per- and polyfluoroalkyl substances (PFAS) to the EPA’s...more
Manufacturing facilities commonly store various chemical substances in aboveground storage tanks. Most facilities ensure chemical storage areas are equipped with proper secondary containment measures to prevent releases of...more
On November 20, 2019, the “PFAS Action Act of 2019” (H.R. 535) (the “PFAS Bill”) passed the House Committee on Energy and Commerce. The PFAS Bill, eighteen subchapters long, says a great deal: most importantly, one year after...more
Regardless of what side of the political fence you reside on and regardless of whether under this current administration you believe environmental enforcement has taken a holiday, the fact remains that most manufacturers...more
The United States Environmental Protection Agency (“EPA”) published a Fact Sheet titled: Amendments to the Emergency Planning and Community Right-to-Know Act - America’s Water Infrastructure Act: A Guide for State...more
Manufacturers and large scale users of hazardous chemicals know the significance of March 1st. The Emergency Planning and Community Right-To-Know Act (EPCRA) requires facilities where hazardous chemicals were present above...more
The United States Environmental Protection Agency (“EPA”) issued a December 26th Federal Register notice adopting a final rule addressing Section 313 of the Emergency Plan and Community Right-To-Know Act (“EPCRA”) Toxics...more
Companies operating ammonia refrigeration systems are easy targets for EPA under a number of environmental programs. Recent history suggests release reporting under Section 112(r) of the Clean Air Act (CAA) and under the...more
EPA is proposing to add Nonylphenol Ethoxylates (NPEs) to the list of Toxic Chemicals under Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA). Comments on the proposal must be received on or...more
CONGRESS FINDS THE FORMULA TO REFORM CHEMICAL REGULATION - The Toxic Substance Control Act (TSCA) is the primary federal law by which the manufacture, import and use of chemical substances are regulated in the United...more
Millard Refrigerated Services Inc. learned the hard way that a company's failure to correct deficiencies in its processes can lead to significant consequences. Following three releases to the atmosphere from 2007 to 2010,...more
EPCRA § 313 requires certain facilities manufacturing or “processing” more than 25,000 lbs. or otherwise using 10,000 lbs or more of a listed toxic chemical to file a Form R annually on or before July 1. In the last two...more