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By James L. Curtis, Adam R. Young, and Craig B. Simonsen

iStock_000011623330_MediumSeyfarth Synopsis: U.S. Chemical Safety Board offers recommendations and best practices for chemical facilities regarding emergency planning and response programs.

The U.S. Chemical Safety Board (the “Board”) is an independent federal agency charged with investigating significant chemical accidents. According to the

By Brent I. Clark, Adam R. Young, and Craig B. Simonsen

iStock_000011623330_MediumThe Occupational Safety and Health Administration has recently released a draft Guidance on Data Evaluation for Weight of Evidence Determination: Application to the 2012 Hazard Communication Standard.

We had previously blogged about OSHA’s 2012 Hazard Communication Standard (HCS), including an Enforcement

By Patrick D. Joyce, Jeryl L. Olson, and Craig B. Simonsen

shutterstock_178475264The 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,

By Andrew H. Perellis and Craig B. Simonsen

Power Lines and Pulp Mill PollutionThe U.S. Government Accountability Office (GAO) has just issued a report on Critical Infrastructure Protection with a finding that Department of Homeland Security (DHS) action is needed to verify chemical facility information and to better manage its compliance process. Report to Congress, GAO-15-614 (July 2015).

Risk Level

By Brent I. Clark, Meagan Newman, and Craig B. Simonsen

iStock_000060649768MediumOSHA has just announced a compliance Directive on “Inspection Procedures for the Hazard Communication Standard,” CPL 02-02-079 (July 9, 2015).

We had previously blogged that June 1, 2015 was the deadline for compliance with the all new hazardous communication (HazCom) standard (29 CFR

By Brent I. Clark, Meagan Newman, and Craig B. Simonsen

bottleThe Occupational Safety and Health Administration issued yesterday an enforcement memo (Memo) and an interim policy (Policy) on the PSM retail exemption.

Tho Memo revised OSHA’s interpretation of the exemption of retail facilities from coverage of the Process Safety Management of Highly Hazardous Chemicals

By Patrick D. Joyce and Craig B. Simonsen

Blog - Fracking WaterThe U.S. Environmental Protection Agency released a draft assessment study last week showing that hydraulic fracturing (“fracking”) activities in the U.S. may have potential impacts on the water lifecycle, affecting drinking water resources. 80 Fed. Reg. 32111 (June 5, 2015).

The report, Assessment of the Potential Impacts