Hazard
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Incorporating PFAS in Industrial Wastewater Discharge Permits to Minimize Risk or Extent of Future CERCLA Liability

PFAS are being detected in drinking water systems across the United States. Moreover, evolving regulatory developments already require or soon will require that public water systems sample for and remediate these chemicals (see, e.g., here). Continue reading
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TSCA Articles Regulations—U.S. EPA Course Reversal?

In prepared remarks from U.S. EPA chemicals chief Michael Freedhoff that were presented at the Product Stewardship Society’s annual meeting, Freedhoff clearly articulated an intent by the Agency to reverse course and aggressively seek to regulate finished articles under the Toxic Substances Control Act (“TSCA”). Continue reading
bioaccumulative and toxic, chemical, compliance, deadline, disposal, Hazard, import, January 2021, manufacturer, March 8 2022, Michael Freedhoff, PBT, persistent, PFAS, polyfluoralklyl, Product Stewardship Society, production volume, regulatory, Section 6(h), Section 8(a)(7), Toxic Substances Control Act, TSCA Articles Regulations, U.S. EPA -
OSHA Issues Immediately Effective COVID-19 National Enforcement Program and Updated Enforcement Guidance: No ETS Yet
On March 12, 2012, OSHA took two significant new actions to enhance its enforcement actions regarding COVID-19 workplace safety: (1) establishing the National Emphasis Program – COVID-19 (the NEP) targeting higher hazard industries for OSHA enforcement action; and (2) updating and replacing its former Interim Enforcement Response Plan for COVID-19 (the Enforcement Plan) to prioritize… Continue reading
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