The U.S. Environmental Protection Agency (EPA) announced on April 9, 2024, the release of an updated “Interim Guidance on the Destruction and Disposal of Perfluoroalkyl and Polyfluoroalkyl Substances and Materials Containing...more
Perfluoroalkyl and polyfluoroalkyl substances (PFAS), commonly known as “forever chemicals,” are a varied group of thousands of manufactured chemicals and have been used in industry and consumer products since the 1940s. In...more
Regulatory activity and litigation concerning per- and polyfluoroalkyl substances (“PFAS”) continued to pick up steam in 2023, and 2024 promises to continue this trend and present companies with new PFAS-related challenges....more
As anticipated, 2021 was an eventful year for the regulation of per- and polyfluoroalkyl substances (“PFAS”) at the federal level. BCLP has highlighted the key developments in this document, but this is not intended to be a...more
The United States Environmental Protection Agency (“EPA”) has outlined additional steps that it plans to take to investigate and in some cases regulate the discharge of per- or polyfluoroalkyl compounds (“PFAS”) in certain...more
Recently, the Center for Biological Diversity filed a lawsuit against the United States Environmental Protection Agency (EPA), claiming that polyvinyl chloride – more commonly known as PVC or vinyl – should be regulated as a...more
In 2020, even the hand sanitizer is potentially suspect. Retailers, distributors and corporate purchasers are now grappling with the added problem of clearing their shelves of it and stopping employees from using the Food and...more
If you are operating in a state where your governor has issued a stay at home order (NY, NJ, CT, CA, PA, IL, OH, MI, LA, DE, KY, WI) and you have been forced to suspend or shutdown some or all of your operations, it is...more
I undertook a presentation on April 17th at the Arkansas Environmental Federation Regulated Waste Seminar titled: Solid and Hazardous Waste Judicial/Regulatory Developments: 2018 – 2019 - The discussion addressed...more
The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) issued a November 7th final rule amending the federal Hazardous Materials Regulations (“HMR”). See 83 Fed. Reg. 55792. The Hazardous...more
The Environmental Protection Agency (EPA) has made several recent changes that will affect compliance obligations under the Resource Conservation and Recovery Act (RCRA). First, EPA finalized revisions to the definition of...more
The United States Environmental Protection Agency (“EPA”) and Blue Ridge Solvents & Coatings, Inc. (“Blue Ridge”) entered into a February 9th Consent Agreement (“CA”) addressing alleged violations of Resource Conservation and...more
Food and drug manufacturing facilities are an increasing target for federal and state environmental enforcement actions. Recent enforcement actions have highlighted the extent to which these facilities are subject to a host...more
The United States Court of Appeals for the District of Columbia Circuit recently rejected portions of an EPA rule designed to distinguish true recycling from “sham recycling” under the Resource Conservation and Recovery Act...more
EPA Issues First Year Implementation Plan - On June 22, 2016, the Frank R. Lautenberg Chemical Safety for the 21st Century Act was signed into law. This law amends the Toxic Substance Control Act (TSCA) and is the first...more
EPA has tentatively denied a petition to expand the test for the hazardous waste characteristic of corrosivity to cover more wastes. In so doing, however, EPA left the door open to reconsider the decision based on public...more
EPA is poised to publish a proposed rule revising regulations applicable to hazardous waste generators under the Resource Conservation and Recovery Act, 42 U.S.C. § 6901 et seq. (RCRA). The proposed rule, which has not yet...more
On August 4, 2015, the U.S. Environmental Protection Agency (EPA) announced the availability of its Final 2014 Effluent Guidelines Program Plan. The Final Program Plan includes the following findings from EPA’s review of...more
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
After years of relative easing in its interpretation of the Resource Conservation and Recovery Act rules that govern industrial recycling, the Environmental Protection Agency is now taking a harder line. A recently issued...more