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“Fair Pay and Safe Workplaces” Rules Head to White House for Final Review

Client Alert | 1 min read | 05.09.16

On May 4, 2016, the FAR Council’s draft final rules and the Department of Labor’s draft final guidance implementing the “Fair Pay and Safe Workplaces” executive order arrived at the White House’s Office of Information and Regulatory Affairs for review, setting in motion the final steps prior to the issuance of burdensome new compliance and reporting obligations for federal contractors and subcontractors (discussed here). OIRA has 90 days to conduct its review of the rules before sending them to the FAR Secretariat for publication, a period during which OFPP and other OMB offices, contractors, and industry trade groups may meet with OIRA to share their concerns, in advance of the publication of new FAR rules likely to trigger vigorous legal challenges from industry.

Insights

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for Releases From Solid Waste Management Units,” under the Resource Conservation and Recovery Act (RCRA).[1] The withdrawn proposal would have revised RCRA corrective action regulations to expressly apply the broader statutory definition of “hazardous waste,” rather than only the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