Disharmony in the Cyber Acquisition Patchwork
Client Alert | 1 min read | 05.07.15
While Executive Order No. 13636 asked for a review of "what steps can be taken to harmonize" existing cyber regulations governing federal acquisitions, a patchwork of more than a dozen different agency regulations – and dozens upon dozens of unpublished cyber policies – impose heavy burdens upon contractors seeking to build cost-effective cybersecurity compliance programs. On May 11, C&M's David Z. Bodenheimer will discuss this analysis and lead a co-sponsored program for the ABA Public Contract Law Section's Cybersecurity, Privacy, and Information Security Committee and the Science & Technology Law Section's Homeland Security Committee on "The Cybersecurity Patchwork of Federal Agency Rules & Unpublished Policies: How Do Contractors Comply?"
Insights
Client Alert | 3 min read | 05.28.26
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Action for Releases From Solid Waste Management Units,” under the Resource Conservation and Recovery Act (RCRA).[1] The withdrawn proposal would have revised RCRA corrective action regulations to expressly apply the broader statutory definition of “hazardous waste,” rather than only the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.
Client Alert | 8 min read | 05.28.26
Texas Targets Big Tech With Wave of Suits and Investigations, Part of Nationwide Trend
Client Alert | 7 min read | 05.27.26
Colorado Hits Reset on AI Regulation: SB 26-189 Repeals and Reenacts the Colorado AI Act
Client Alert | 3 min read | 05.27.26
Don’t Get Left in the Doghouse: The Federal Circuit’s Global K9 Case and the Duty to Intervene
