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The State of the Union, Suspension and Debarment Edition

Client Alert | less than 1 min read | 06.22.16

On June 15, 2016, the Interagency Suspension and Debarment Committee transmitted its annual report to Congress concerning the status of the federal suspension and debarment system, known as the “873 Report” after section 873 of Public Law 110-417, which requires the annual reporting. The 873 report evidences a slight decline in suspensions, proposed debarments, and debarments from FY 2014 to FY 2015, and an overall increase in the use of “alternatives to exclusion” such as administrative agreements (up 25 percent), and show cause letters (up 30 percent).

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for Releases From Solid Waste Management Units,” under the Resource Conservation and Recovery Act (RCRA).[1] The withdrawn proposal would have revised RCRA corrective action regulations to expressly apply the broader statutory definition of “hazardous waste,” rather than only the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