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SPCC—Lessons Learned

An oil production company operating in Big Horn County, Wyoming was recently fined for the discharge of approximately 162 barrels of oil into a tributary of a major river. The discharge came from a leak in a pipeline at its pumping facility. The facility is on an onshore oil gathering, pumping, and storage station that […]

EPA Rescinds Previous CWA Guidance Requirements

The EPA on September 16 rescinded its guidance document entitled “Applying the Supreme Court’s County of Maui v. Hawaii Wildlife Fund Decision in the Clean Water Act Section 402 National Pollutant Discharge Elimination System Permit Program.” This guidance document was issued on January 14, 2021, by the Trump administration. “Using the tools provided by the […]

E-Enterprise: What They’re Saying

The U.S. Environmental Protection Agency (EPA) is in the process of trying to modernize its approach to environmental compliance and efficiency through a project called “E-Enterprise.” Yesterday we looked at the basic premises of E-Enterprise and how it will affect the regulated community. Today we will review some of the comments the EPA has received […]

Chemicals

Ability to Request CBI Expanded Under TSCA

The June 2016 amendments to the Toxic Substances Control Act (TSCA) expanded the categories of persons who may request confidential business information (CBI) about chemicals, which regulated entities submitted to the EPA.

What the SEC Says about Reporting Climate Change Risks

Peabody Energy Corporation, the largest publicly traded coal company in the world, was recently muscled by the state of New York into revising its shareholder disclosures with the Securities and Exchange Commission (SEC) to include financial risks associated with climate change and potential regulations. Yesterday we reviewed SEC risk disclosure requirements. Today we will discuss […]

California, Oregon Alert Employers to Heat Hazards

State occupational safety and health regulators in California and Oregon reminded employers to protect workers from heat hazards and comply with their states’ heat illness prevention standards. On June 2, the Oregon Occupation​al Safety and Health Administration (Oregon OSHA) announced the release of employer assistance resources for the state’s new heat illness prevention rule. The […]

Part 109 Rules for Oil Spill Response Resources

In addition to the personnel requirements we reviewed yesterday, Part 109 also defines how facilities that do not have a Facility Response Plan (FRP) in place and that have made the determination that required secondary containment is impracticable,  should both have and be prepared to obtain necessary spill response equipment. In general, according to the […]

Asbestos Removal

Cutting Corners with Asbestos Removal Leads to Huge Fines

State regulators say a Seattle hotel owner who knew his building contained asbestos cut corners to save money by using untrained workers to remove it. As a result, the Department of Labor and Industries (L&I), which runs the Washington state OSHA program, cited the business for multiple egregious safety and health violations and issued $355,000 […]