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West Virginia v. EPA: What This Means for Federal Agency Rulemaking Going Forward

​​​​​​​The U.S. Supreme Court’s decision in West Virginia v. EPA has received much press as a decision that limits regulations designed to address climate change. But in reality, it was not so much an environmental law case...more

Emerging Chemical Issues – Ethylene Oxide (Part 5 of 5): OIG, EPA and the Consequences of Premature Public Disclosures

U.S. EPA has recently come under fire from its quasi-independent auditor, the Office of the Inspector General (OIG), which has issued multiple reports accusing EPA of not moving with sufficient speed or transparency to...more

Emerging Chemical Issues – Ethylene Oxide (Part 4 of 5): Special Considerations Related to the Sterilization Industry

Commercial sterilization operations find themselves in a more unique and complex regulatory context than many other industrial sources of EtO. Unlike the chemical manufacturing industry, which can often make decisions about...more

Emerging Chemical Issues – Ethylene Oxide (Part 3 of 5): Challenges to the IRIS EtO URE

Today’s alert looks at the current status of challenges to the IRIS EtO URE and EPA’s related rulemaking proceedings. Sterilizers have been one of the most widely publicized sources of EtO, and have taken the brunt of...more

Emerging Chemical Issues – Ethylene Oxide (Part 2 of 5): A Patchwork of State Regulation

Federal law generally sets a floor, rather than a ceiling, when it comes to emission reduction regulations, and thus, when assessing a facility’s compliance and legal risks it is important to track state and local laws,...more

Emerging Chemical Issues – Ethylene Oxide (Part 1 of 5): Why It Matters

In the past two years, hundreds of lawsuits have been filed against companies based on their emissions of a chemical called ethylene oxide (often referred to as “EtO” or “EO”). Multiple facilities that handle EtO also have...more

Hardly Ever? Permitting of Indirect Discharges Under the Clean Water Act After County of Maui, Hawaii v. Hawaii Wildlife Fund

The Supreme Court’s most recent voyage into Clean Water Act (CWA) jurisprudence came in County of Maui, Hawaii v. Hawaii Wildlife Fund, 590 U. S. ____ (2020) (Slip Op.), which concerned whether CWA permits are required in...more

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