News & Analysis as of

Proposed Rules Manufacturers Environmental Protection Agency (EPA)

Mitchell, Williams, Selig, Gates & Woodyard,...

Project Emissions Counting/Clean Air Act: Steel Manufacturers Association Comments on U.S. Environmental Protection Agency...

The Steel Manufacturers Association (“SMA”) submitted July 2nd comments to the United States Environmental Protection Agency (“EPA”) addressing the proposed rule styled: Prevention of Signification Deterioration (PSD) and...more

Goldberg Segalla

Don’t you know that you’re toxic? EPA spears most uses of controversial solvent.

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In late April, the U.S. Environmental Protection Agency issued a ban on most uses of methylene chloride, a toxic solvent used for paint stripping and linked to over 85 deaths in the last 45 years. The ban forbids all consumer...more

Goldberg Segalla

EPA’s Final EtO Rule Finally Finalized

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The Environmental Protection Agency on March 14 announced final amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) applicable to 90 large commercial sterilization facilities that use ethylene...more

Holland & Knight LLP

2023 PFAS Year in Review: EPA Policy and Aqueous Film-Forming Foam Litigation Updates

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2023 was a busy year for folks following legal developments related to per- and polyfluoroalkyl substances (PFAS). In December, the U.S. Environmental Protection Agency (EPA) issued its Second Annual Progress Report. Some of...more

Bergeson & Campbell, P.C.

EPA Proposes to Amend PBT Rules for decaBDE and PIP (3:1)

On November 24, 2023, the U.S. Environmental Protection Agency (EPA) published a proposed rule that will amend the regulations for decabromodiphenyl ether (decaBDE) and phenol, isopropylated phosphate (3:1) (PIP (3:1)), two...more

Mitchell, Williams, Selig, Gates & Woodyard,...

U.S. EPA Proposed NSPS/NESHAP for Synthetic Organic Chemical Manufacturing Industry: American Chemistry Council/Fuel and...

The American Chemistry Council, American Fuel & Petrochemical Manufacturers, U.S. Tire Manufacturers Association, and Vinyl Institute (collectively “ACC”) submitted July 7th comments to the United States Environmental...more

Kilpatrick

Another Vote for Business Casual? EPA’s Proposed Ban on Perchloroethylene for Dry Cleaning and Other Uses

Kilpatrick on

The use of a mainstay of the dry-cleaning industry – perchloroethylene – may be coming to an end.  On June 16, 2023, EPA proposed to ban, under the Toxic Substance Control Act’s Section 6(a) authority, most uses of...more

Beveridge & Diamond PC

EPA Leverages Controversial IRIS Value for Ethylene Oxide to Fast-Track Overhaul of Clean Air Act Regulations of Chemical...

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Last week, the U.S. Environmental Protection Agency (EPA) issued a 444-page pre-publication summary of new proposed rules intended to reduce hazardous air emissions from chemical manufacturers in the Synthetic Organic...more

Goldberg Segalla

In Pursuit of a Final Rule: EPA Requests Additional Comments on Chrysotile Asbestos

Goldberg Segalla on

Chrysotile asbestos is the only known form of asbestos imported into the United States. It is found in a variety of products, such as sheet gaskets, brake blocks, and aftermarket brakes and linings. The chlor-alkali industry...more

Jenner & Block

Maine Proposed Rule Provides Further Reporting Clarity for Products and Product Components Containing PFAS

Jenner & Block on

On February 14, 2023, the Maine Department of Environmental Protection (MDEP) issued a proposed draft rule that provides guidance on reporting requirements and sales prohibitions for products and product components containing...more

Bergeson & Campbell, P.C.

EPA Seeks Comment on Initial Regulatory Flexibility Analysis on Proposed PFAS Reporting Rule

On November 25, 2022, the U.S. Environmental Protection Agency (EPA) announced the availability of and solicited comment on an Initial Regulatory Flexibility Analysis (IRFA) and Updated Economic Analysis following the...more

Smith Gambrell Russell

EPA to Increase Chemical Manufacturer’s Fees

Smith Gambrell Russell on

On Tuesday, November 14, the EPA issued a proposed rule which would increase fees charged under the Toxic Substances Control Act (TSCA) to manufacturers and handlers of chemical substances. The proposed rule would more than...more

Beveridge & Diamond PC

EPA Hints at Critical Changes to TSCA PFAS Reporting Rule, Seeks Comment

Beveridge & Diamond PC on

The U.S. Environmental Protection Agency's (EPA) June 2021 proposal of a Toxic Substances Control Act (TSCA) reporting rule targeting manufacturers of per- and polyfluoroalkyl substances (PFAS) sparked a major outcry from...more

Foley & Lardner LLP

Foley Manufacturing Update - November 2022

Foley & Lardner LLP on

The most recent article in Foley & Lardner’s Supply Chain Disruption Series provides background on a number of key terms and conditions for buyers and sellers in the supply chain to consider in commercial forms. Click here to...more

Bergeson & Campbell, P.C.

Proposed Rule Concerning CBI Claims under TSCA Addresses Purpose of New Part 703 and Requirements for Asserting a Confidentiality...

On May 12, 2022, the U.S. Environmental Protection Agency (EPA) proposed new and amended requirements concerning the assertion and treatment of confidential business information (CBI) claims for information reported to or...more

Clark Hill PLC

EPA Proposes Updates to Air Toxics and Performance Standards For Lead Acid Battery Plants

Clark Hill PLC on

On Feb. 11, EPA proposed updates to both the National Emissions Standards for Hazardous Air Pollutants (NESHAP) that apply to Lead Acid Battery (LAB) Manufacturing Area Sources (Subpart PPPPPP) and the New Source Performance...more

Kelley Drye & Warren LLP

EPA Proposes Extension Until 2024 for Compliance with Problematic PBT Rule

Kelley Drye & Warren LLP on

As the U.S. EPA embarks on a full review of regulations addressing the sale, distribution and use of five “persistent, bioaccumulative and toxic” (PBT) substances, the agency already is proposing to extend until 2024 the...more

BCLP

PFAS Update: EPA Proposes Reporting on the Last 10 Years of Manufacture or Import of Products Containing PFAS

BCLP on

The Environmental Protection Agency (“EPA”) is proposing new reporting requirements for Per- and Polyfluoroalkyl Substances (“PFAS”) that would require manufacturers, including importers, to report on their manufacture or...more

Kilpatrick

TSCA’s Information Grab – Manufacturers and Importers Subject to Proposed Expansive Ten-Year “Look Back” PFAS Reporting...

Kilpatrick on

Did you manufacture or import a water repellant t-shirt or a nonstick cooking pan or high performance mountain wear in the past ten years? If so, you could be required to provide ten years of past data and details regarding...more

Foley & Lardner LLP

Foley Weekly Automotive Report - August 2021 - 2

Foley & Lardner LLP on

This report helps automotive suppliers inform their legal and operational decisions to help address challenges and opportunities. Key Developments - U.S. new light vehicle sales in July fell to an estimated SAAR of 14.5...more

Woods Rogers

EPA Proposes Retroactive PFAS Reporting

Woods Rogers on

On June 28, 2021, the U.S. Environmental Protection Agency (“EPA”) published a proposed rule that would require a one-time report from companies that manufactured or imported per- and polyfluoroalkyl substances (PFAS) in any...more

Snell & Wilmer

EPA to Collect PFAS Manufacturing Data

Snell & Wilmer on

On June 10, 2021, the U.S. Environmental Protection Agency’s (EPA) announced three actions demonstrating its commitment to help reduce the potential risks to the public from per- and polyfluoroalkyl substances (PFAS)... ...more

Bergeson & Campbell, P.C.

EPA Announces Three PFAS Actions, Including Proposed TSCA Section 8(a) Reporting Rule

The U.S. Environmental Protection Agency (EPA) announced on June 10, 2021, three actions intended to protect communities from per- and polyfluoroalkyl substances (PFAS). The actions include proposing a rule designed to obtain...more

Jackson Lewis P.C.

Manufacturers Should Prepare For OSHA’s New And Altered Proposed Hazard Communication Requirements

Jackson Lewis P.C. on

Manufacturers, suppliers, distributors, and importers have often struggled with communicating product hazards to downstream employees and users, due to complex hazard communication requirements in international standards, as...more

Steptoe & Johnson PLLC

EPA Introduces Additional Action Items Under Its 2019 PFAS Action Plan

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On January 19, 2021, the United States Environmental Protection Agency (“EPA”) introduced several new action items to further complement its progress under the 2019 Per-and Polyfluoroalkyl Substances ("PFAS") Action Plan....more

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