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Proposal To Further Executive Branch Employees' Acceptance Of Gifts From Lobbyists

Client Alert | 1 min read | 09.14.11

On September 13, 2011, the Office of Government Ethics proposed amendments to the regulation governing the acceptance of gifts by executive branch employees for the purpose of (a) implementing the lobbyist gift ban already applicable, by Executive Order of the President, to most political appointees; and (b) imposing limits on the use of gift exceptions by all executive branch employees (not merely political appointees). The proposed rule would render existing exceptions to the gift restrictions inapplicable when the gift giver is both a prohibited source (e.g., a person doing business with the employee’s agency) and a lobbyist or lobbying organization, thus limiting the use of exceptions such as the $20 de minimis exception, the widely attended gathering exception, the social invitation exception, and the exception for meals, refreshments, and entertainment from private entities in a foreign area.

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for Releases From Solid Waste Management Units,” under the Resource Conservation and Recovery Act (RCRA).[1] The withdrawn proposal would have revised RCRA corrective action regulations to expressly apply the broader statutory definition of “hazardous waste,” rather than only the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