By Patrick D. Joyce, Jeryl L. Olson, and Craig B. Simonsen
The U.S. Environmental Protection Agency this week released a pre-publication copy of a proposed rule on pharmaceutical hazardous wastes in healthcare and related industries that will significantly affect our healthcare clients. 80 Fed. Reg. 58014 (Sept. 25, 2015).
Under the proposed rule, aimed at hospitals, clinics, nursing … Continue Reading
By Patrick D. Joyce and Craig B. Simonsen
The U.S. EPA announced earlier this week a proposed rule to reduce emissions of greenhouse gases (GHG) and volatile organic compounds (VOC) from the oil and natural gas industry. The proposal is nearly 600 pages long. Proposed rule (August 18, 2015).
The proposed rule will add methane to the list of gasses … Continue Reading
By Philip L. Comella
Today, the U.S. Environmental Protection Agency issued two proposed rules lowering the threshold at which landfills must control methane gas emissions.
For active landfills, EPA proposes to reduce the threshold from 50 metric tons of non-methane organic compounds annually to 34 metric tons. As a practical matter, this means that roughly 100 active landfills – with … Continue Reading