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SBA Regulatory Changes Affect Relationships Between Small and Large Businesses

Client Alert | 1 min read | 06.09.16

On May 31, 2016, SBA published the final rule, effective June 30, implementing the National Defense Authorization Act of 2013. Considering the critical importance of these changes on size status and teaming relationships between large and small businesses, Crowell & Moring is posting a series of blog posts to cover the wide range of impacts that this rule will have on such topics as limitations on subcontracting, small business subcontracting plans, penalties, affiliation, and the non-manufacturer rule.

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for Releases From Solid Waste Management Units,” under the Resource Conservation and Recovery Act (RCRA).[1] The withdrawn proposal would have revised RCRA corrective action regulations to expressly apply the broader statutory definition of “hazardous waste,” rather than only the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