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Closure Plan

Q. Are there compliance issues that would prevent our installation of a compressor on a concrete slab on which our (now clean-closed) RCRA-permitted hazardous waste boiler sat? Our Closure Plan states that we will close the slab when the facility closes.

TSCA Fee Schedule Set in Final Rule

The 2016 amendments to the Toxic Substances Control Act (TSCA) require that the EPA charge fees to persons who either submit information the Agency must review or manufacture chemicals for which the Agency must conduct risk evaluations. The EPA has now published a final rule that establishes fees for certain activities under TSCA Sections 4, […]

NIOSH: 1 in 5 Non-Healthcare Workers May Be Exposed to COVID-19

Workers’ occupation, industry, and specific job duties factor into how physically close to others they must work, whether they need to interact with the public, and whether they are potentially exposed to infectious diseases like COVID-19, according to new research from the National Institute for Occupational Safety and Health (NIOSH). In what may be the […]

The Return of SEPs

Early in March 2022, the EPA and the Department of Justice (DOJ) announced the return of the use of Supplemental Environmental Projects (SEP) as part of the available resources that can be utilized in enforcement actions. “An SEP is an enforcement tool that EPA used for more than 30 years until the previous administration brought […]

General Safety Review

The year’s end provides a good time to revisit general safety principles with your workers. Begin with the basics: There are two types of general hazards on the job: unsafe acts and unsafe conditions. Unsafe acts are actions workers take that ignore safety procedures and risk their own or co-workers’ health and safety. They include […]

OSHA Cites New Jersey Facility, Seeking $574K Penalty

The Occupational Safety and Health Administration (OSHA) announced October 6 it cited Pennsylvania-based metal coatings manufacturer Regal Industrial Corp. for 5 willful, 15 serious, and 1 other-than-serious violation at its Millvale, New Jersey, facility, seeking $573,681 in proposed penalties. The willful citations relate to respirator, written hazard communication program, safety data sheet (SDS), fall protection, […]

Shell Board Members Personally Sued Over Claims of Mismanaged Climate Strategy

ClientEarth filed suit in February 2023 in the Court of England and Wales against the board members of Shell PLC for failing to manage the material and foreseeable risks posed to the company by climate change. The lawsuit, the first known attempt to hold board members personally liable, “alleges Shell’s 11 directors have breached their […]

Brownfields Redevelopment: Turning to Land Banks for Innovation

At the close of its 2017 regular legislative session, the Connecticut General Assembly adopted an increasingly popular nationwide trend in brownfields remediation and redevelopment. By establishing the framework for a state brownfields land bank program, the Connecticut legislation represents a shift in the way brownfields projects are being administered around the country. With reduced budgets […]