On May 12, 2025, the U.S. Environmental Protection Agency (EPA) announced an amendment delaying the data submission period for the Toxic Substances Control Act (TSCA) PFAS reporting rule, which will now begin on April 13, 2026, and end on October 13, 2026. Small manufacturers who report solely as article importers will have until April 13
Administrators May Change, But PFAS Is Forever: EPA Announces PFAS Plan
The U.S. Environmental Protection Agency (EPA), under Administrator Lee Zeldin, has unveiled its anticipated strategy for addressing the pervasive issue of per- and polyfluoroalkyl substances (PFAS), often referred to as “forever chemicals.” While the announcement provides a broad framework, specific details (particularly regarding potential changes to previous rulemakings under CERCLA and the Safe Drinking Water
Environmental, Health, and Safety Outlook for 2025
In putting together our thoughts on this post, it was hard not to think about the elephant in the room (see what I did there?). The change in administration has already brought significant changes in our nation’s environmental priorities. While time will show us all of the specific ways this will play out in 2025
EPA Releases PFAS Strategic Roadmap Third Annual Report
- Designation
PFOA and PFOS Are CERCLA Hazardous Substances – Now What?
EPA recently issued its long-awaited rule designating perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) as hazardous substances under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). Along with the rule, EPA issued PFAS Enforcement Discretion and Settlement Policy Under CERCLA. This policy document provides the regulated community with some insight as to how
EPA Seeks Public Comment on Environmental Justice Guidance
The EPA is seeking comments on a newly released, revised guidance document regarding the consideration of environmental justice (EJ) concerns in the rulemaking process. The guidance document updates a 2016 version and incorporates new scientific developments, other EPA guidance, and new priorities and policies.
The guidance document sets forth both analytical expectations for an EJ
EPA Power Plant Ruling Could Have Broader Effects for Industry
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
EPA Establishes New Health Advisories for PFAS
Earlier this month, EPA set new lifetime health advisories for four per- and poly-fluoroalkyl substances (PFAS) – in some instances at levels lower than those that can be detected through laboratory testing. The new health advisories are listed below:
| PFAS | Health Advisory (in parts per trillion) |
| PFOA (perflurooctanoic acid) | 0.004 ppt |
| PFOS (perfluorooctane sulfonic acid) |
SEC Proposed Rule on Climate-Related Disclosures: A Look at Scope 3 Emissions Reporting Requirements
True to its word, the SEC released its proposed rule, The Enhancement and Standardization of Climate-Related Disclosures for Investors, last week. The rule would require companies to disclose a wide variety of climate-related information, including information about climate-related risks that are reasonably likely to have material impacts on its business and/or its consolidated financial
OSHA Withdraws Vaccination and Testing ETS
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