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CERCLA Release Reporting Exemption for Federally Permitted Releases

Seasoned environmental professionals are well-acquainted with the typical hazardous substance release reporting analysis under CERCLA; where a reportable quantity of a hazardous substance is released into the environment...more

Environmental Notes - December 2022

EPA Proposes to Expand TRI Reporting Requirements for PFAS and Other Chemicals of Special Concern - EPA is proposing to add per- and polyfluoroalkyl substances (“PFAS”) subject to reporting under the Emergency Planning...more

Unpacking the TSCA Polymer Exemption

Manufacturers of chemical substances in the United States are well aware of the regulatory burdens placed on their industry by the Toxic Substances Control Act (TSCA). TSCA requirements can be cumbersome and difficult to...more

Beat the Clock: Timely Reporting of Releases of Hazardous Substances

The obligation of manufacturing facilities to report releases of hazardous substances to local, state, or federal authorities is a complex regulatory subject. Multiple variables may impact whether a facility with a release to...more

EPA Amends TSCA Definition of “Small Manufacturer”

EPA recently issued a final rule amending Toxic Substances Control Act (TSCA) regulations concerning “small manufacturers” of chemical substances. Companies that meet the regulatory definition of a “small manufacturer” of...more

EPA Issues Temporary Advisory for NPDES Reporting During COVID-19

We recently provided a summary of EPA’s guidance entitled COVID-19 Implications for EPA’s Enforcement and Compliance Assurance Program. In this initial guidance, EPA reminded the regulated community that, while it was...more

Containment Area Releases and the Limits of CERCLA Release Reporting Obligations

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

Environmental Notes - January 2019

EPA recently released a final regional office realignment plan in response to President Trump’s March 2017 Executive Order 13781. That order required EPA and other federal agencies to improve efficiency, effectiveness, and...more

EPA Issues TSCA PMN Guidance: Pointers for Submitters

EPA recently published guidance for companies preparing to submit new chemical notifications pursuant to the Toxic Substance Control Act (TSCA). The guidance, entitled Points to Consider When Preparing TSCA New Chemical...more

Know Your Chemical’s Potential without TSCA Oversight: The Test Marketing Exemption Explained

Manufacturers, importers and processors of chemical substances in the United States, know full well the regulatory burdens placed on their industry by the Toxic Substances Control Act (TSCA). TSCA requirements can be...more

Tips for Tackling Tier II Trouble

Companies with hazardous chemical reporting obligations know the significance of March 1. On that date each year, facilities that at any time during the prior year had 10,000 pounds or more of an OSHA hazardous chemical, or...more

Environmental Notes - June 2015

In this Issue: - EPA Issues SIP Call to Eliminate SSM Defense - EPA and Corps Define “Waters of The United States” - Frequent Questions: EPCRA 313 - Generators Need to be Vigilant About TCLP Sampling...more

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