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A Focus on Multinationals: Adding Enterprise Value Through Global Whistleblower Protocols and Promoting Employer Values

Client Alert | 1 min read | 11.12.21

Whistleblower activity—including new whistleblower laws—has increased in recent years; however, the number of internal whistleblower complaints has fallen. Internal whistleblower complaints are an opportunity for employers to correct misconduct, noncompliance, or other workplace problems as they happen. While this presents a challenge for employers, it is also an opportunity to reevaluate internal policies, training, and workplace culture. In this article, the second installment of a two-part series, Director of Global Corporate Compliance for Corning, Inc., Dan Christmas, along with Crowell’s Preston Pugh, Trina Fairley-Barlow, and Rachel Lesser, discuss strategies for maximizing the benefits and minimizing the risks of increased whistleblower activity. Part one of this series, available here, reviews the rise in whistleblower bounty laws and other laws designed to incentivize reporting.

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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Action for Releases From Solid Waste Management Units,” under the Resource Conservation and Recovery Act (RCRA).[1] The withdrawn proposal would have revised RCRA corrective action regulations to expressly apply the broader statutory definition of “hazardous waste,” rather than only the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....

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