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Breaking Down EPA's Latest Proposed Rules: Expanded Hazardous Waste Definitions and PFAS Listings
On February 8, 2024, the United States Environmental Protection Agency (EPA) published two proposed rules under the Resource Conservation and Recovery Act (RCRA) that will expand the regulatory definition of “hazardous waste” and add nine per- and po...
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Proposed Prop 65 Pose Increased Litigation Risks
California’s Office of Environmental Health Hazard Assessment (OEHHA) has proposed changes to the short form warnings currently permitted by Proposition 65. These changes have the potential to greatly raise the cost of doing business in California....
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EPA Approves the Use of ASTM E1527-21 for the All Appropriate Inquiries Requirement
On February 13, 2023, the Environmental Protection Agency’s (EPA) final rule amending the All Appropriate Inquiries (AAI) rule took effect. Under the new rule, prospective purchasers of contaminated property can use ASTM E1527-21 “Standard Practice f...
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EPA Issues Historic Proposed Rule to Designate PFOS and PFOA as Hazardous Substances Under CERCLA
On August 26, 2022, EPA issued its long-awaited notice of proposed rulemaking to designate two commonly used per- and polyfluoralkyl substances (PFAS)—i.e., PFOS and PFOA, including their salts and structural isomers—as “hazardous substances” under C...
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EPA Issues New HAL for Four Commonly Used PFAS
After months of speculation, on June 15, 2022, EPA issued its drinking water health advisory for four commonly used PFAS: PFOA, PFOS, GenX, and PFBS. EPA’s drinking water health advisories provide information on the levels of a specific contaminant t...
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PFAS Roundup: A Brief Summary of the Standards Set by Western States for PFAS in the Environment
Per- and polyfluoralkyl substances (PFAS) are everywhere. PFAS are a large group of chemicals that have been in use by a variety of industries since the 1940s for their ability to resist heat, oil, stains, grease, and water. For example, in...
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