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It is not unusual for a developing rule or other agency action to be something of a moving target, with an agency responding to comments in a way that leaves some in the regulated community complaining that they did not receive the required fair opportunity to comment before the rule or agency action became final.

science laboratory glasswareWith the 2020 reporting period under the Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) rule rapidly approaching, the US Environmental Protection Agency (US EPA) has announced a number of key changes to the information that chemical manufacturers and importers must submit to the agency pursuant to the CDR rule.  US EPA also announced

California agencies are beginning to provide clarification and directives to guide regulatory compliance following local “shelter in place” orders to slow the spread of COVID-19 in the San Francisco Bay Area, and Governor Gavin Newsom’s state-wide “stay at home” order issued on March 19, 2020. While the State Department of Public Health is taking the

Following Governor Abbott’s recent proclamation of a state of disaster in Texas due to the COVID-19 pandemic, both the Texas Commission on Environmental Quality (TCEQ) and the Railroad Commission of Texas (RRC) have issued guidance for regulated entities relating to environmental compliance concerns as well as other useful information relative to agency operations during these

Over the past week and in just the last 24 hours, several federal and state agencies have issued guidance documents and orders impacting the oil and gas pipeline industry. Through this guidance and other orders, federal and state governments are recognizing the oil and gas industry as critical to responding to COVID-19, while at the

As the coronavirus (COVID-19) outbreak continues across the U.S., it is important for companies to proactively address the potential disruptions to their compliance programs. Environmental compliance is often a boots-on-the-ground activity; but what happens when those boots are at home, can’t travel as needed, or can’t observe operations at the plant level?  Unprecedented staffing and

The Louisiana Department of Environmental Quality (“LDEQ”) issued an Emergency and Administrative Order on March 19, 2020, to address hardships posed to regulated facilities by efforts to combat the COVID-19 virus. See the order here. The Order expires on April 18, 2020. The Order may be extended and/or amended as the situation evolves. At