By Jeryl L. Olson

In follow-up to our blog earlier this week on the EPA’s January 13, 2015 new Final Rule on the Definition of Solid Waste (DSW rule), this is to discuss the new “remanufacturing exclusion” as it relates to certain solvents under 40 CFR § 261.4(a)(27).

The  § 261.4(a)(27) exclusion is specifically addressed at certain “higher
Continue Reading Remanufacturing Exclusion for Solvents Under New Definition of Solid Waste Rules

By Ilana R. Morady and Craig B. Simonsen

Oil Tanker Train CarsThe U.S. Department of Transportation (DOT) yesterday released details of a “comprehensive rulemaking proposal to improve the safe transportation of large quantities of flammable materials by rail – particularly crude oil and ethanol.”

According to DOT Secretary Anthony Foxx “safety is our top priority, which is why I’ve worked aggressively to improve
Continue Reading Transportation Department Proposes Big Changes to Rail Transportation of Crude Oil and Flammable Materials

By Jeryl L. Olson and William R. Schubert

The U.S. Environmental Protection Agency has proposed its renewable fuel standards for the year 2013.  The proposed rule would require producers, importers, and distributors of gasoline and diesel to add greater proportions of renewable fuels to their products.

The 2013 proposed rule includes a standard for the nationwide volume of “cellulosic biofuel”
Continue Reading EPA Proposes 2013 Renewable Fuel Standards