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FAR Amended to Standardize Past Performance Evaluations

Client Alert | less than 1 min read | 08.05.13

On August 1, 2013, the FAR was amended to provide for standardized past performance evaluation factors and performance rating categories for use government-wide and to require that past performance information be entered into the Contractor Performance Assessment Reporting System (CPARS). The final rule, which becomes effective on September 3, 2013, leaves intact the existing process to appeal an evaluation and places an emphasis on monitoring the quality and timeliness of submission of past performance information.


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Client Alert | 3 min read | 05.28.26

PFAS Regulatory Alert: EPA Rolls Back RCRA Proposed Rule on “Hazardous Waste” but Does Not Disturb Proposed RCRA Rule on PFAS

Earlier this month, the U.S. Environmental Protection Agency (EPA) withdrew a February 2024 Biden administration proposed rule, “Definition of Hazardous Waste Applicable to Corrective Action for Releases From Solid Waste Management Units,” under the Resource Conservation and Recovery Act (RCRA).[1] The withdrawn proposal would have revised RCRA corrective action regulations to expressly apply the broader statutory definition of “hazardous waste,” rather than only the narrower regulatory definition. Now, EPA is maintaining the status quo for corrective action under RCRA. However, EPA’s withdrawal of its proposed RCRA hazardous waste definition makes no mention of its corresponding proposal from 2024 to list nine per- and polyfluoroalkyl substances (PFAS) as RCRA hazardous constituents.[2] This disjointed withdrawal, while providing some certainty for regulated entities, does not resolve how EPA plans to address PFAS under the RCRA program....