By James L. Curtis, Adam R. Young, and Craig B. Simonsen
Seyfarth Synopsis: With a larger base of compliance officers, OSHA has significantly increased its ability to conduct on-site inspections and reorient its enforcement strategies.
OSHA’s budget was essentially flat during the Trump Administration. As health care costs increased and compliance safety and health officers retired, OSHA struggled
Continue Reading OSHA Significantly Increases the Number of InvestigatorsBy Andrew H. Perellis, Jeryl L. Olson, Patrick D. Joyce, and Craig B. Simonsen
Seyfarth Synopsis: On June 29, 2020, U.S. Environmental Protection Agency (EPA) issued a memorandum regarding termination of the COVID-19 temporary enforcement policy. EPA has selected August 31, 2020 as the termination date for its temporary enforcement policy. Also updated were EPA’s Frequent
Continue Reading EPA Ends Enforcement Discretion Policy for COVID-19 Pandemic on August 31
By Andrew H. Perellis, Jeryl L. Olson, Patrick D. Joyce, and Craig B. Simonsen
Seyfarth Synopsis: The U.S. Centers for Disease Control and Prevention (CDC) and the U.S. Environmental Protection Agency (EPA) jointly developed and released guidance that is generally intended for everybody, whether a business, a school, a
Continue Reading Joint CDC/EPA Guidance for Cleaning and Disinfecting Public Spaces, Workplaces, Businesses, Schools, and Homes
By Andrew H. Perellis, Jeryl L. Olson, Patrick D. Joyce, and Craig B. Simonsen
Seyfarth Synopsis: The U.S. Environmental Protection Agency (EPA), in response to the COVID-19 pandemic, has announced interim guidance for the Agency’s regional offices to “ensure that decisions about new or ongoing cleanup activities at sites across the country are made with the
Continue Reading EPA Guidance Concludes COVID-19 Can Constitute Force Majeure Event for Parties Performing CERCLA/RCRA Remediation
By Jeryl L. Olson, Andrew H. Perellis, Patrick D. Joyce, and Craig B. Simonsen
Seyfarth Synopsis: U.S. Environmental Protection Agency (EPA), in support of the U.S. Government’s overall response to the COVID-19 pandemic, has announced a temporary enforcement discretion policy regarding environmental legal obligations during the COVID-19 pandemic.
EPA’s recently-released temporary enforcement discretion policy, COVID-19 Implications
Continue Reading EPA Enforcement Discretion Policy for COVID-19 Pandemic
By James L. Curtis, Brent I. Clark, and Craig B. Simonsen
Seyfarth Synopsis: OSHA is sponsoring a “Safe + Sound Week,” another example of a more cooperative approach to worker safety and health issues.
We had blogged previously on OSHA’s launch of the “Safe and Sound Campaign” webpage, calling on employers to review their safety
Continue Reading OSHA Schedules First “Safe + Sound Week”
By Brent I. Clark and Craig B. Simonsen
Seyfarth Synopsis: OSHA has recently “launched” a “Campaign for Safety & Health Programs,” that it indicates is an approach that has been proven by “best in class” employers to reduce injuries and illnesses and improve their businesses.
In a recent news release out of OSHA’s Region 7, it notes that OSHA’s
Continue Reading OSHA Promotes “Safe and Sound Campaign” to Assist Employers — A Change in Approach?
By Wan Li, Andrew S. Boutros, Kay R. Bonza, and Craig B. Simonsen
Seyfarth Synopsis: The Chinese Ministry of Environmental Protection has just announced criminal, civil, and administrative enforcement statistics, and put companies on notice that those who violate environmental laws and rules may face blacklisting, including restrictions to their future business endeavors.
We have previously written
Continue Reading New Eye-Popping Statistics: Multinationals Operating in China Should be Aware of Increased Enforcement of Chinese Environmental Laws as Well as the Potential for Blacklisting
By Wan Li, Andrew H. Perellis, and Craig B. Simonsen
In the last twelve months the Ministry of Environmental Protection (MEP) in the People’s Republic of China (PRC) has been remarkably vocal about environmental law, monitoring, and fraud, especially under the new environmental law and supplemental measures.
For instance, the MEP announced on June 16, 2015, that
Continue Reading Multinationals in China Should be Aware of Increased Enforcement of Environmental Law, Monitoring Requirements – and Fraud
By Andrew H. Perellis and Craig B. Simonsen
The 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 for Facilities
The Report states
Continue Reading DHS Chemical Facilities Take Note GAO Suggested Need For Enhanced Enforcement