By Jeryl L. Olson
Following pressure from Environmental Groups and Congress, the U.S. Environmental Protection Agency has announced two rule changes affecting users of refrigerants containing ozone depleting substances (ODS) (chlorofluorocarbons or “CFCs” and hydrochlorofluoro-carbons or “HCFCs”).
On October 20, 2014, EPA announced the phase out of the production, import, and export of certain HCFCs between 2015 and 2019, and … Continue Reading
By Andrew H. Perellis and Craig B. Simonsen
In another proposal aimed at small business, the U.S. Environmental Protection Agency has just proposed a rule for Effluent Limitations Guidelines and Standards for the Dental Category. 79 Fed. Reg. 63258 (October 22, 2014). The rule will add more federal compliance costs and potential local treatment facility user fees to already tight … Continue Reading
By Andrew H. Perellis, Jeryl L. Olson, and Ilana R. Morady
On October 6, 2014, EPA finalized an amendment to the “All Appropriate Inquiries” (AAI) rule to remove the reference to ASTM E-1527-05. 79 Fed. Reg. 60087. This means that ASTM E-1527-05 is no longer adequate to establish landowner and lender liability protections under CERLA. Buyers, sellers, … Continue Reading