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You’re Not Hired! President Trump Imposes Executive Agency Hiring Freeze

Client Alert | 1 min read | 01.24.17

On January 23, 2017, President Trump issued a memorandum imposing a freeze, which prohibits all executive agencies from hiring federal civilian employees to fill positions that were vacant as of noon on January 22, 2017 or creating new positions. Though agencies are forbidden from “[c]ontracting outside the government to circumvent” this prohibition, some exemptions exist, namely for military personnel, for positions that executive agency and department heads deem “necessary to meet national security or public safety responsibilities[,]” and as the Office of Personnel Management Director determines are “otherwise necessary.” Per the memorandum, the freeze is scheduled to expire upon implementation of a long-term Office of Management and Budget (OMB) plan “to reduce the size of the Federal Government’s workforce through attrition[,]” which OMB must recommend within 90 days of the memorandum’s date.

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for Releases From Solid Waste Management Units,” under the Resource Conservation and Recovery Act (RCRA).[1] The withdrawn proposal would have revised RCRA corrective action regulations to expressly apply the broader statutory definition of “hazardous waste,” rather than only the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