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Costs Of Influencing Collective Bargaining Decisions Proposed For Disallowance

Client Alert | less than 1 min read | 04.22.10

To implement the provisions of Executive Order No. 13494, Economy in Government Contracting, the FAR Council has proposed changes to the labor relations cost principle, FAR 31.205-21, expressly to disallow the costs of activities to persuade employees to exercise or not to exercise their collective bargaining rights, such as the costs of preparing and distributing materials, legal and consultant fees, costs of meetings (including salaries of attendees), and planning and conducting activities by managers, supervisors, or union representatives during working hours. Comments on the proposed rule are due June 14, 2010.

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for Releases From Solid Waste Management Units,” under the Resource Conservation and Recovery Act (RCRA).[1] The withdrawn proposal would have revised RCRA corrective action regulations to expressly apply the broader statutory definition of “hazardous waste,” rather than only the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