Category: Special Topics in Environmental Management

Principles for NAAQS Reviews Clarified by Pruitt

The EPA only recently issued almost all the remaining area designations for the 2015 National Ambient Air Quality Standards (NAAQS) for ozone (only eight counties in the San Antonio, Texas, area have not been designated). Now, with the ink barely dry on those designations, the Agency is facing yet another Clean Air Act (CAA) deadline […]

Coal mine

GAO Urging Congress to End Self-Insurance for Coal Mines

Self-insurance as a means for mining companies to show regulators that funds will be available to remediate damage to the environment caused by industrial activities is coming under increasing scrutiny and is not holding up well under the magnifying glass.

Pesticide label

Do You Understand Placement of Pesticide First-Aid Statements?

Inclusion of first-aid statements on pesticide labels is governed by regulations at 40 CFR 156.68. The fundamental requirement is that all pesticides that have “systemic effects in Category I, II, or III, or skin or eye irritation effects in Category I or II” must bear a first-aid statement. (Category I pesticides have high toxicity; Category […]


USCG Says There’s No Value in Ballast Reporting Rule

The U.S. Coast Guard (USCG) is proposing to eliminate the third-year requirement of a 3-year regulation that compels owners and operators of vessels operating on voyages exclusively between ports or places within a single Captain of the Port (COTP) zone to submit an Annual Ballast Water Summary Report.


Vacatur of SNAP Rule Clarified

In a notice, the EPA reports that it has received requests for regulatory clarity from stakeholders that are uncertain about how the D.C. Circuit’s August 8, 2017, opinion in Mexichem Fluor Inc. v. EPA affects their compliance obligations under an Agency 2015 rule that amended the federal Significant New Alternatives Policy (SNAP) program on ozone-depleting […]

Scientific research

The EPA, Regulatory Science, and Transparency

EPA Administrator Scott Pruitt has followed through on a commitment he made last month to initiate rulemaking to limit the Agency’s use of scientific information that is not accessible to the public and, therefore, not available for independent verification.


CO Emissions Limit in Boiler MACT Remanded by D.C. Panel

A panel of the U.S. Court of Appeals for the D.C. Circuit ordered the EPA to review a surrogate emissions limit in the Agency’s 2015 revisions to its 2013 National Emissions Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters (Boiler MACT [maximum achievable control technology]).