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EPA Enforcement Plans and More...

Updated: Dec 4, 2023

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EPA Proposes Procedural Changes for Chemical Risk Evaluation Under TSCA

October 31, 2023

EPA is proposing to amend the procedural framework outlined in 40 CFR 702, Subpart B for conducting risk evaluations under the Toxic Substances Control Act (TSCA). The purpose of risk evaluations under TSCA is to determine whether a chemical substance presents an unreasonable risk of injury to health or the environment.

Source: EPA

EPA Finalizes Restrictions on the Use of Certain Hydrofluorocarbons

October 25, 2023

EPA is finalizing regulations that would implement provisions of the American Innovation and Manufacturing (AIM) Act of 2020. The new regulations restrict the use of hydrofluorocarbons (HFCs) in specific sectors or subsectors in which they are used and establish a process for submitting petitions for restrictions on the use of regulated substances. In addition, the EPA is establishing labeling, recordkeeping, and reporting requirements.

Source: EPA

EPA Publishes Comprehensive PFAS Reporting Rule Under TSCA

October 17, 2023

The U.S. Environmental Protection Agency (EPA) published a final rule that requires comprehensive reporting by manufacturers and importers of the more than 1,000 per- and polyfluoroalkyl substances (PFAS) manufactured and imported in the United States since 2011 under the Toxic Substances Control Act (TSCA). Reporting entities are likely to need all 18 months allocated by EPA to come close to meeting the reporting obligation, as well as to build compliance systems to address ongoing requirements.

8 Essential RCRA Records for Generators

October 6, 2023

RCRA Recordkeeping Essentials guide gives you crucial details about four important paperwork requirements for facilities that generate hazardous waste—personnel training records, the hazardous waste contingency plan, waste determination records, and the Biennial Report.

Source: Lion

Proposed Revisions to NSPS for Volatile Organic Liquid Storage Vessels

October 5, 2023

EPA is proposing a new NSPS Subpart for volatile organic liquid (VOL) storage vessels (40 CFR 60, Subpart Kc). In the new NSPS subpart, EPA is proposing to reduce the vapor pressure applicability thresholds; to revise the volatile organic compound (VOC) standards to reflect the best system of emissions reductions (BSER) for affected storage vessels; additional monitoring and operating requirements; degassing emission controls; to clarify startup, shutdown, and malfunction requirements; requirements for electronic reporting; and other technical improvements. EPA is also proposing to amend the existing NSPS Subpart for VOL storage vessels (40 CFR 60, Subpart Kb) to reflect the addition of the new Subpart and to add electronic reporting requirements.

Source: EPA

Prepare Now for Even More Aggressive EPA Enforcement

October 3, 2023

Companies should take note and be prepared to respond quickly to more—and more aggressive—EPA enforcement, on the heels of two new enforcement initiatives announced by David Uhlmann, the recently confirmed Assistant Administrator for the U.S. Environmental Protection Agency (EPA)’s Office of Enforcement and Compliance Assurance (OECA). Just a month following confirmation, Uhlmann has rolled out EPA’s FY 2024-2027 National Enforcement and Compliance Initiatives (NECIs), highlighting six environmental priorities (climate change, PFAS exposure, coal ash, air toxics in overburdened communities, drinking water compliance, and chemical accident risk reduction), and the Climate Enforcement and Compliance Strategy, which prioritizes climate change in all EPA enforcement and compliance efforts.

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OSHA Reveals Top 10 Safety Violations at NSC Congress & Expo

October 24, 2023

At the NSC Expo in October, OSHA revealed the ten most cited workplace health and safety violations for fiscal year 2023. This year's list shows a substantial increase in violations of the most-cited Standards.

Source: NSC


Agency Guidelines Confirm that Climate-Related Financial Risk Is Real

October 31, 2023

The U.S. Department of the Treasury's Office of the Controller of the Currency, Federal Reserve Board and Federal Deposit Insurance Corp. have issued joint guidelines on climate-related financial risk for large financial institutions.

The guidelines encourage large financial institutions to develop their own procedures to identify, measure, monitor and control for climate-related financial risks and ensure that their public statements are consistent with internal strategies, risk appetite statements and risk management frameworks. The guidelines also describe how climate-related financial risks can be addressed in various risk categories, including credit, liquidity, operational, legal and compliance, along with other financial and nonfinancial risks.

TNFD Recommendations for Nature Related Disclosures

October 21, 2023

On September 18, 2023, the Taskforce on Nature-related Financial Disclosures (TNFD) published recommendations for organizations’ assessment, management, and disclosure of nature-related issues (the Recommendations). These recommendations were the result of a two-year engagement process, featuring several beta versions to receive and process commentary from a range of stakeholders. The process builds on several years of growing attention to the fundamental role of nature — including the 2022 Global Biodiversity Framework that nearly 200 countries adopted in a Paris Agreement-type moment for nature.

ESG Reports Will Soon Require Third-Party Assurance. Here’s How to Get Ready

October 11, 2023

The biggest challenge associated with new ESG reporting regulations isn’t that companies will be compelled to disclose ESG data — many already do so voluntarily — it is that they will need to have their ESG reports "assured," which means the data will be subject to the same scrutiny as financial reporting.

New regulations, such as the European Union’s Corporate Sustainability Reporting Directive and anticipated rules from the U.S. Securities and Exchange Commission and California, will require corporations to get third-party assurance for their climate and ESG-related disclosures. The aim is to elevate the accuracy and legitimacy of ESG disclosures to standards that investors and regulators have come to expect for corporate financial reporting.

Source: GreenBiz

Reducing the Risk of ‘Greenwashing’ Litigation and Defending Actions That Are Filed

October 10, 2023

"Greenwashing” refers to the practice of making false or misleading claims about the environmental benefits of a product in order to represent it as more environmentally friendly than it actually is. Given consumers’ increasing environmental sensibilities, it is unsurprising that greenwashing has become a major source of litigation.

Government agencies (e.g., the Federal Trade Commission (FTC) and state attorneys general) sometimes assert greenwashing challenges on their own initiative. Most of the time, however, private attorneys file greenwashing lawsuits as class actions. These lawsuits largely focus on claims like “environmentally responsible,” “sustainably sourced” and “humanely raised,” arguing that these false environmental claims induce consumers to pay a premium for “greener” products. Source: Harvard Law School Forum on Corporate Governance

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