gguilford's blog

EPA Announces Important New Policy on TSCA CBI Claims of Deficiency

Tue, 07/16/2019 - 16:57

The U.S. Environmental Protection Agency (EPA) announced on July 15, 2019, that it will cease sending notices of deficiency to businesses that submit procedurally flawed confidential business information (CBI) claims under the Toxic Substances Control Act (TSCA). This is a significant change from the interpretation EPA announced in January 2017, and a company’s failure to appreciate its consequences could prove damaging.

Government Contracts Regulatory and Legislative Update For June 2019

Tue, 07/16/2019 - 10:45

REGULATIONSDoD Issues Proposed Rule Establishing Preference for Fixed-Price ContractsOn April 1, 2019, the U.S. Department of Defense (DoD) issued a proposed rule to revise the Defense Federal Acquisition Regulation Supplement (DFARS) to establish a preference for fixed-price contracts when determining contract type, and to require use of firm fixed-price contracts for foreign military sales, subject to exceptions.

EPA’s Enforcement Statistics and Priorities – the Trump Administration’s Shift in Focus Toward Collaboration and Greater Coordination with the States

Tue, 07/16/2019 - 10:44

Over the last few months, EPA’s enforcement priorities under the Trump Administration have come into sharper focus. The Fiscal Year 2018 Enforcement Annual Results offer a snapshot of a full year of the agency’s enforcement activity under Senate-confirmed leadership.

PFAS Solution Moving Through Congress on Must-Pass Defense Bill

Mon, 07/15/2019 - 15:35

PFAS (perfluoroalkyl and polyfluoroalkyl substances) have been under scrutiny on both sides of the Capitol in recent months, and the Senate made significant headway in late June in reaching consensus on PFAS legislation.  Following two hearings in the Senate Environment and Public Works (EPW) Committee this spring, a package was unveiled and quickly considered in Committee on June 19. Championed by EPW Chairman John Barrasso (R-WY), Ranking Member Tom Carper (D-DE), and Senator Shelley Moore Capito (R-WV), S.

EPA, Intervenors File Supplemental Briefs in Case Challenging EPA’s Prioritization and Risk Evaluation Rules

Mon, 07/15/2019 - 15:33

On June 28, 2019, the U.S. Environmental Protection Agency (EPA) filed its response to the non-governmental organizations’ (NGO) supplemental brief in a case challenging EPA’s prioritization and risk evaluation rules.  Safer Chemicals, Healthy Families v. EPA, No.

Hazardous Materials Supply Chain: Emergency Telephone Numbers in EU’s GSH/SDSs

Wed, 07/03/2019 - 17:03

By Abdul H. Khalid, PhD, CHMM, RPIHWhat do you know about an emergency telephone number given in a Safety Data Sheets (SDSs) of a hazardous materials supply chain worldwide?European Union (EU) requires emergency telephone numbers in the Safety Data Sheets (SDSs) globally, as referenced in the Global Harmonization System (GHS) of the Classification, Labeling, and Packaging (CLP); the EU CLP Regulations.Emergency contact or telephone number in the SDSs is required by the manufactures, producer, importers, suppliers or distributors in the section one (1) of the SDSs.

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