Category: Regulatory Developments

The What and When of Revised Refrigerant Regulations

The U.S. Environmental Protection Agency (EPA) recently finalized broad changes to its refrigerant management regulations under 40 CFR 82. Those owning, operating, maintaining, servicing, repairing, or disposing of air-conditioning and refrigeration equipment will all be impacted by these revisions. The most significant change extends the regulations for ozone-depleting refrigerants to non-ozone- depleting substitutes through an […]

EPA Names Five PBT Chemicals for Expedited Action

The new section 6(h) of the Frank R. Lautenberg Chemical Safety for the 21st Century Act, which greatly expanded the reach of the Toxic Substances Control Act (TSCA), requires that within 3 years of the June 22, 2016, date of enactment, the U.S. Environmental Protection Agency (EPA) must propose rules to reduce risks (by reducing […]

EHS on Tap Episode 11: OSHA’s New Recordkeeping Rule–Whats in Store for Drug Testing and Employer Retaliation?

On this episode of EHS on Tap, OSHA’s new recordkeeping rule—what’s in store for drug testing and employer retaliation, we address OSHA’s recent rulemaking on reporting injuries in the workplace and how work-related injuries can trigger drug testing and employer retaliation. We speak with attorney Adele Abrams. Adele heads a nine-attorney firm that represents employers […]

PSM Retail Exemption Update

A little over a year ago, OSHA issued a memorandum revising the agency’s interpretation of the PSM standard’s retail facility exemption.  However, on September 23, 2016, the U.S. Court of Appeals for the D.C. Circuit vacated the agency’s revised interpretation.

EPA Proposes Fixes for GHG Permitting Regs

In its continuing effort to bring its Clean Air Act (CAA) greenhouse gas (GHG) regulations in line with the U.S. Supreme Court’s ruling in Utility Air Regulatory Group v. EPA (UARG v. EPA), the Agency is proposing several amendments to provisions in its Prevention of Significant Deterioration (PSD) program. Essentially, the proposal describes specific conditions […]

Compliance Deadline Extended for UOG Wells

The EPA has issued a direct final rule extending the compliance deadline for onshore unconventional oil and gas (UOG) extraction wells subject to the Agency’s June 28, 2016, final pretreatment effluent limitations guidelines (ELGs). Under the direct final rule, UOG facilities—including wells that are hydraulically fractured—that were lawfully discharging to publicly owned treatment works (POTWs) […]

EHS on Tap: Episode 10: The Clean Power Plan: What the D.C. Circuit Court’s Recent Hearing Means for Clean Air

On this episode of EHS on Tap, we speak with Joe MacDougald, a Professor in Residence on the faculty of the UConn Law School and the Executive Director of the Center for Energy and Environmental Law about the D.C. Circuit Court’s en banc review of the Environmental Protection Agency’s most ambitious regulatory initiative and a […]