On December 27th, the President signed into law a second pandemic relief package as part of a larger government funding bill passed by Congress entitled The Consolidated Appropriations Act, 2021 (“CAA”). In March of this year, President Trump signed the first pandemic-related stimulus bill: H.R. 748, the Coronavirus Aid, Relief and Economic Security Act (Public
CAA
Chemical Safety Board’s New Release Reporting Rules in Effect March 2020
By Maureen Harbourt & Lauren Rucinski on
Posted in Environmental Litigation and Regulation
Starting March 23, 2020, facilities must add one more agency to the list of those that may need to be notified in the event of an accidental release: The U.S. Chemical Safety Board (“CSB”).The CSB was established by the 1990 Clean Air Act (“CAA”) Amendments.[1] The CAA directs the CSB, among other things, to…
RMP Reconsidered (Proposal) – What are the Takeaways?
By Kean Miller on
Posted in OSHA, Process Safety Management
On May 30, 2018, the Environmental Protection Agency (EPA) published proposed revisions to the Risk Management Program (RMP) rules that would largely undo changes to the (stayed) final rule published on January 13, 2017. See 83 Fed. Reg. 24850 (May 30, 2018). Although not a complete one hundred eighty degree U-turn, the revised proposed…
EPA’s Major Shift on New Source Review Permitting Policy
By Kean Miller on
Posted in Environmental Litigation and Regulation
On December 7, 2017, the Environmental Protection Agency (“EPA”) released a memorandum entitled, “New Source Review Preconstruction Permitting Requirements: Enforceability and Use of the Actual-to-Projected-Actual Applicability Test in Determining Major Modification Applicability.”[1] In the NSR memo, EPA announced its intention to drop its long-standing position that the Agency can use its own…