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Déjà Vu: Congress Orders DCAA to Revise Guidance on Access to Internal Audit Reports

Client Alert | less than 1 min read | 01.15.13

Section 832 of the FY 2013 NDAA requires DCAA to issue new guidance on access to contractors' internal audit reports to "ensure" that requests for access to them "are appropriately documented," following guidance issued by the agency in August 2012. The revised guidance will require DCAA to keep tabs on such requests and responses to them, but sets limits on what internal audit reports can be used for and stops short of language in the Senate version of the bill, under which the contractor's refusal to provide access would have been "a basis for disapproving the contractor business system or systems."


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Client Alert | 5 min read | 08.26.26

D.C. Circuit Upholds Designation of PFOA and PFOS as CERCLA Hazardous Substances

In a significant and unanimous ruling, the D.C. Circuit upheld the Environmental Protection Agency’s (“EPA”) final rule designating perfluorooctanoic acid (“PFOA”) and perfluorooctanesulfonic acid (“PFOS”) as “hazardous substances” under the Comprehensive Environmental Response, Compensation, and Liability Act (“CERCLA”), denying the petitions of seven industry groups seeking to overturn that designation.[1] CERCLA, also known as the “Superfund Statute,” allows EPA to require potentially responsible parties to fund cleanup of hazardous substances....