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Proposed NRO Clause Would Require Broad Disclosure -- Comments Due Tomorrow

Client Alert | 1 min read | 02.12.04

The proposal of the National Reconnaissance Office (NRO) to add a new standard clause to its contracts that would provide that "contractors and their employees, agents, representatives, subcontractors, and employees of subcontractors shall report to the NRO Inspector General (IG) or General Counsel any and all possible violations of federal criminal law or illegal intelligence activities of which they become aware during performance under an NRO contract," make all relevant records and employees available to the IG (failure to do so grounds for default termination), and flow the clause down to subcontractors raises obvious and serious policy issues. The request for comments are due tomorrow, February 13, despite only being published on February 4, on the NRO website, where the full text of the proposed clause is available.

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for Releases From Solid Waste Management Units,” under the Resource Conservation and Recovery Act (RCRA).[1] The withdrawn proposal would have revised RCRA corrective action regulations to expressly apply the broader statutory definition of “hazardous waste,” rather than only the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