By 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 Jeryl L. Olson, Andrew H. Perellis, Patrick D. Joyce, Rebecca A. Davis, Ilana R. Morady, and Craig B. Simonsen
Seyfarth Synopsis: Last week, the U.S. Environmental Protection Agency (EPA or Agency) initiated the first phase of a two phased approach to address ethylene oxide (EtO) emissions, announcing final amendments to the Miscellaneous Organic
Continue Reading EPA Promulgates Final Rule on Miscellaneous Organic Chemical Manufacturing NESHAP – Including Ethylene Oxide
By Jeryl L. Olson, Andrew H. Perellis, Patrick D. Joyce, and Craig B. Simonsen
Seyfarth Synopsis: This U.S. Environmental Protection Agency (EPA) announced its final rule to add per- and polyfluoroalkyl substances (PFAS) to the list of chemicals required to be reported annually under the EPCRA Section 313 Toxics Release Inventory (TRI) reporting requirements, and established
Continue Reading EPA Adds PFAS to 313 Reporting for 2020
By Jeryl L. Olson, Andrew H. Perellis, Patrick D. Joyce, and Craig B. Simonsen
Seyfarth Synopsis: This U.S. Environmental Protection Agency (EPA) proposed rule would provide “procedures for developing and issuing guidance documents and to establish a petition process for public requests to modify or withdraw an active guidance document.”
We have previously blogged on agency
Continue Reading EPA Proposes Rule to “Improve Transparency” of Agency Guidance Documents
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 Rebecca A. Davis, Brent I. Clark, Jeryl L. Olson, Patrick D. Joyce, Ilana R. Morady, and Kay R. Bonza
Seyfarth Synopsis: The United States Environmental Protection Agency (EPA) released a list of disinfectants to use against SARS-CoV-2, the novel coronavirus that causes COVID-19.
EPA today released a list of disinfectants to use against
Continue Reading EPA Releases List of Disinfectants to Use Against SARS-CoV-2, the Virus that Causes the COVID-19 Disease
By Jeryl L. Olson, Kay R. Bonza, and Craig B. Simonsen
Seyfarth Synopsis: The U.S. Chemical Safety and Hazard Investigation Board (CSB) has proposed new accidental chemical release reporting requirements that are broad in scope and would cover additional chemicals, lower threshold quantities, and more areas within a stationary source than existing regulatory release reporting requirements already
Continue Reading ANOTHER Chemical Release Reporting Obligation????
By Jeryl L. Olson, Ilana R. Morady, Kay R. Bonza, and Craig B. Simonsen
Seyfarth Synopsis: On December 20, 2019, the National Defense Authorization Act for Fiscal Year 2020 (NDAA) was signed into law, including provisions for adding certain per- and polyfluoroalkyl substances (PFAS) to the EPA’s Toxic Release Inventory (TRI) list of reportable chemicals under
Continue Reading NDAttention – National Defense Authorization Act (NDAA) Adds Per- and Polyfluoroalkyl Chemicals to TRI