1. Home
  2. |Insights
  3. |Proposed Rule and Guidance Issued for Implementing "Fair Pay and Safe Workplaces" Executive Order

Proposed Rule and Guidance Issued for Implementing "Fair Pay and Safe Workplaces" Executive Order

Client Alert | 1 min read | 05.28.15

Today, the Obama Administration published the highly anticipated notice of proposed rulemaking (NPRM) and guidance for implementing the "Fair Pay and Safe Workplaces Executive Order," starting the clock on a 60-day notice and comment period. The NPRM and related guidance (available by PDF here and here and explained in more detail on our government contracts blog) would add onerous labor compliance reporting requirements for contractors and subcontractors on contracts valued over $500,000 (and on non-COTS subcontracts valued over $500,000), inject subjectivity into the contract award process through the addition of "Agency Labor Compliance Advisors" advising the CO with respect to responsibility determinations, limit contractors' right to arbitrate certain employment disputes, and add new "paycheck transparency" requirements for contractors.


Contacts

Insights

Client Alert | 3 min read | 04.25.24

JUST RELEASED: EPA’s Bold New Strategic Civil-Criminal Enforcement Collaboration Policy

The Environmental Protection Agency’s (EPA’s) Office of Enforcement and Compliance Assurance (OECA) just issued its new Strategic Civil-Criminal Enforcement Policy, setting the stage for the new manner in which the agency manages its pollution investigations. David M. Uhlmann, the head of OECA, signed the Policy memorandum on April 17, 2024, in order to ensure that EPA’s civil and criminal enforcement offices collaborate efficiently and consistently in cases across the nation. The Policy states, “EPA must exercise enforcement discretion reasonably when deciding whether a particular matter warrants criminal, civil, or administrative enforcement. Criminal enforcement should be reserved for the most egregious violations.” ...

View All Insights