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OFCCP Issues "Internet Applicant" Definition

Client Alert | less than 1 min read | 10.10.05

The Office of Federal Contract Compliance Programs ("OFCCP") issued a final rule on October 7, 2005, clarifying the definition of an "applicant" in the context of internet recruitment and amending recordkeeping requirements regarding internet applications. This long-awaited clarification narrows the applicant definition previously utilized by the OFCCP, but will require many contractors to modify existing data collection and recordkeeping practices by February 6, 2006, so contractors should initiate a comprehensive review of their selection, applicant tracking, and record retention processes promptly to ensure compliance with this new rule.

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for Releases From Solid Waste Management Units,” under the Resource Conservation and Recovery Act (RCRA).[1] The withdrawn proposal would have revised RCRA corrective action regulations to expressly apply the broader statutory definition of “hazardous waste,” rather than only the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