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Cyber Regs Toughened Up

Client Alert | less than 1 min read | 03.13.12

As Congress continues to mull competing proposals for new cyber legislation, federal agencies have moved ahead under existing statutory authority to tighten and toughen the regulations and standards governing cybersecurity for government contractors. In a recent Briefing Paper published by Thomson West, David Bodenheimer and Jon Baker of Crowell & Moring address the escalating cyber threats driving this trend, the existing statutory and regulatory framework imposing information security requirements, and the fundamental elements necessary for a sound cybersecurity program -- including compliance procedures, continuous monitoring, and security controls specified by the National Institute of Standards and Technology (NIST).


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for Releases From Solid Waste Management Units,” under the Resource Conservation and Recovery Act (RCRA).[1] The withdrawn proposal would have revised RCRA corrective action regulations to expressly apply the broader statutory definition of “hazardous waste,” rather than only the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