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I am a Partner in the Robinson+Cole’s Environmental, Energy + Telecommunications Group. I focus my practice on environmental compliance counseling, permitting, site remediation, occupational health and safety, energy regulatory compliance and siting, and litigation related to federal and state regulatory programs. My experiences working on complex matters for over a decade enable me to work effectively with experts and legal counsel to help clients minimize risk and solve compliance, enforcement, transactional, and regulatory matters. My full firm bio can be accessed here.

The U.S. Environmental Protection Agency (EPA) released an advance notice of proposed rulemaking with a focus on modifying the treatment and handling of “empty” containers and drums under the Resource Conservation and Recovery Act (RCRA). The EPA is soliciting information and requesting comments “to assist in the potential development of non-regulatory and regulatory options that

The EPA intends to increase its review of voluntary self-disclosures of violations submitted electronically under EPA’s Audit Policy. The EPA Office of Inspector General (OIG) recently issued a report detailing the results of an evaluation of EPA’s process for screening self-reported environmental violations made through its eDisclosure system. The OIG’s report concluded that EPA

Below is an excerpt of an article co-authored with Jon Schaefer and published in Industry Week on July 8, 2022.  Jon focuses his practice on environmental compliance counseling, occupational health and safety, permitting, site remediation, and litigation related to federal and state regulatory programs.

Last week, the U.S. Supreme Court issued its decision that the Environmental

The U.S. EPA unveiled a new notification service this week called ECHO Notify. This new tool will allow the public to receive weekly e-mails notifying them of EPA- and state-led environmental enforcement actions and violations. A subscriber can request to be notified based on a specific EPA Facility ID, ZIP code, county, or state.

As covered in my previous post, the ASTM International (ASTM) released a revised standard for conducting Phase I Environmental Site Assessments (Phase I ESAs) – ASTM E1527-21. While the E1527-21 standard has been available for use since November, it has not been officially included in the CERCLA regulations as satisfying the All Appropriate Inquiries

Throughout the first year of the Biden-Harris Administration, Environmental Justice (EJ) has been a focus of the U.S. Environmental Protection Agency. As I wrote about in November 2021, since January 2021 EPA has released numerous policies and guidance documents on EJ-related issues and has taken unprecedented actions in connection with permitting reviews and enforcement

Effective January 26, 2022, OSHA withdrew its enforcement of its COVID-19 Emergency Temporary Standard (ETS), which would have required many employers to mandate vaccination or regular testing for employees. As we have previously discussed, the ETS had undergone a number of legal challenges. Most recently the United States Supreme Court stayed the ETS and

As we have previously reported, the implementation status of OSHA’s Emergency Temporary Standard (ETS) regarding COVID-19 vaccination or testing seems to change weekly. Yesterday, the United States Supreme Court reinstated the stay of OSHA’s ETS, ultimately sending the rule back to the Sixth Circuit to await a full review on the merits.

In the