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Just past the halfway point of 2024, it's already been a busy year for those following regulatory developments related to per- and polyfluoroalkyl substances (PFAS). Building on its plans in the 2021 PFAS Strategic Road Map...more
The clock is winding down on businesses interested in commenting on EPA’s proposal to designate nine per- and polyfluoroalkyl substances (PFAS) as hazardous constituents under the Resource Conservation and Recover Act (RCRA)....more
On February 8, 2024, the Environmental Protection Agency (EPA) published two proposed rules that would expand its regulatory authority over PFAS: one to list nine PFAS as hazardous constituents subject to the Resource...more
The proposed rules would expand the RCRA Corrective Action regime to PFAS and potentially other emerging contaminants. They may complicate ongoing compliance efforts as well as lead to significant value chain impacts....more
The 1984 Hazardous and Solid Waste Amendments amended the Resource Conservation and Recovery Act (RCRA) to add the following sections requiring corrective action for releases of hazardous waste or hazardous constituents ...more
On February 8, 2024, the Environmental Protection Agency ("EPA") proposed two regulations that would add nine per- and polyfluoroalkyl substances ("PFAS") to the list of Resource Conservation and Recovery Act ("RCRA")...more
On February 8, 2024, the U.S. Environmental Protection Agency (EPA) proposed two rules to expand the Agency’s authority to address releases of per- and polyfluoroalkyl substances (PFAS) and other emerging contaminants at...more
The US Environmental Protection Agency (EPA) published on February 8, 2024 two proposed rules addressing per- and polyfluoroalkyl substances (PFAS) under the Resource Conservation and Recovery Act (RCRA). The rules, if...more
The U.S. Environmental Protection Agency (EPA) has taken its first major action of 2024 to regulate per- and polyfluoroalkyl substances (PFAS) across environmental media. On January 31, 2024, EPA issued pre-publication...more
On January 31, 2024, the Environmental Protection Agency ("EPA") proposed two new rules that would add nine per- and polyfluoroalkyl compounds (known as "PFAS") to its list of hazardous constituents regulated under the...more
On January 31, 2024, the United States Environmental Protection Agency (“EPA” or “the Agency”) issued a proposal to amend Resource Conservation and Recovery Act (“RCRA”) regulations to include nine specific per- and...more
The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) submitted comments to the United States Environmental Protection Agency (“EPA”) on November 22 addressing the following Advance Notice of...more
The Alliance for Chemical Distribution (“ACD”) submitted comments to the United States Environmental Protection Agency (“EPA”) on November 17th addressing the following Advance Notice of Proposed Rulemaking (“ANPR”): ...more
Almost two years ago, we posted on the civil settlement of a dispute between the New Mexico Environment Department (NMED) and the U.S. Department of Defense (DoD) over a state-level enforcement action against Cannon Air Force...more
A few considerations practitioners should keep in mind when dealing with contamination involving per- and polyfluoroalkyl substances (PFAS) contamination. The PFAS Action Act of 2021 passed in the House and was received in...more
EPA announced plans to initiate two rulemakings involving PFAS, one that would list four PFAS compounds as Hazardous Constituents under the Resource Conservation and Recovery Act (RCRA), the federal hazardous waste law, and...more
The American Chemistry Council (“ACC”) issued a guidance document titled: Guidelines for Management and Disposal of Hazardous Wastes from Polyurethane Processing (“Guidelines”) ...more
The Environmental Protection Agency (EPA) has promulgated its proposed regulation of “hazardous waste pharmaceuticals,” i.e., pharmaceutical residues discarded from health care facilities which also meet EPA’s long-standing...more
As we reported last year, the U.S. EPA has stepped up its enforcement activity under the risk management provisions of the Clean Air Act (“CAA”), Section 112(r), focusing on both the Risk Management Plan (“RMP”) program rules...more