On December 6, 2024, the Office of Environmental Health Hazard Assessment, the lead agency that implements Proposition 65, announced new amendments to the Proposition 65 “short-form” warning requirements....more
Exploring Trends in California’s Proposition 65: Claims, Chemicals, Products, and More - California’s Proposition 65 (“Prop. 65”), the Safe Drinking Water and Toxic Enforcement Act of 1986, requires, among other things,...more
The Alabama Department of Environmental Management (“ADEM”) and West Fraser US EWP LLC (“West Fraser”) entered into a November 6th Consent Order (“CO”) addressing alleged violations of an air permit. See Consent Order No....more
Peter Murphy’s 1989 single, “Cuts You Up,” came to mind when we read FDA’s Office of Prescription Drug Promotion’s (“OPDP”) latest Notice of Violation....more
There are several forms of communications FDA may send to signify an issue. FDA may send a company a notice of a violation in the form of a Warning Letter, an Untitled Letter, or an “It Has Come to Our Attention” Letter. Any...more
The United States District Court for the Eastern District of Virginia (“Court”) addressed in an August 15th Opinion a Clean Water Act jurisdictional question. See United States v. Chameleon, LLC, No. 3:23-CV-763–HEH, 2024 WL...more
The Tennessee Department of Environment and Conservation (“TDEC”) issued a proposed September 20th Director’s Order and Assessment (“Order”) addressing Tennessee River Investors (“TRI”) alleging violation of the Tennessee...more
In 1984, the international rock band, The Scorpions, released the song, “Rock You Like a Hurricane.” Forty years later, the Food and Drug Administration’s Office of Prescription Drug Promotion rocked a pharmaceutical company...more
The Alabama Department of Environmental Management (“ADEM”) and Ecovery, LLC (“Ecovery”) entered into an August 7th Consent Order (“CO”) addressing an alleged violation of an Air Permit. The CO provides that Ecovery...more
The United States Department of Justice on behalf of the United States Environmental Protection Agency (“EPA”) and Gershow Recycling Corporation (“GRC”) entered into an August 20th Consent Judgment (“CJ”) addressing alleged...more
The Missouri Department of Natural Resources (“MDNR”) issued an August 8th Administrative Order on Consent (“AOC”) to Gemini Marine, LLC d/b/a Polestar Marina (“Polestar”) addressing alleged violations of the regulations...more
Much like how Ray Charles lamented in 1967, the pharmaceutical industry is saying, “Here we go again, she’s back in town again,” as the Food and Drug Administration issued its second Notice of Violation in a month. Last week,...more
On July 26, 2024, OFCCP published Directive 2024-01: Expedited Conciliation Procedures (the “Directive”). The Directive is intended to “outline updated procedures for an expedited conciliation option, giving contractors and...more
The Missouri Department of Natural Resources (“MDNR”) issued an Order of Suspension of Permit (“Order”) to Welker Pump Service (“Welker”). See Order No. WIS-2024-006. The Order provides that Welker is the responsible...more
On July 26th, OFCCP issued Directive 2024-01, which outlines new procedures for expedited conciliation, with the option to enter into an Expedited Resolution Conciliation Agreement (ERCA). Through the expedited conciliation...more
In 1987, the influential garage rock band, The Replacements, led by Paul Westerberg, sang, “I can’t hardly wait.” Years later, the Food and Drug Administration issued a Notice of Violation — the second this year — to a...more
On July 30, 2024, the U.S. EPA Office of Inspector General issued a fraud alert to bring attention to an increasing number of companies reporting that they have received fraudulent EPA Notice of Violation letters demanding...more
Phishing scams can pop up anywhere, as evidenced by the U.S. Environmental Protection Agency (EPA) Office of Inspector General’s recent alert regarding fraudulent Notice of Violation letters (NOVs)....more
The Alabama Department of Environmental Management (“ADEM”) and Qualawash Holdings, LLC (“QH”) entered into a Consent Order (“CO”) addressing alleged violations of the Alabama Administrative Code addressing hazardous waste....more
The Colorado Department of Health & Environment (“CDPH&E”) issued a June 6th Notice of Violation/Cease and Desist Order (“NOV”) to the Turquoise Connection, Inc. (“TCI”) addressing alleged violations of the Colorado Water...more