Charles Merrill

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Throughout Charlie’s legal career, most of his work has been for manufacturing and technology clients, such as manufacturers of organic and inorganic chemicals, engineered products, metals and military ordnance. In recent years, he has provided ongoing environmental legal support to chemical products and engineered products companies that lack in-house environmental legal resources.

Latest Articles

Cannabis businesses may be surprised to learn that Proposition 65, the California law that seeks to warn consumers of chemicals in the products they buy, may apply to many marijuana products.  This law requires all parties in the supply chain, from manufacturers to distributors (but not retailers except in certain circumstances) to place warning labels on products sold in California if those products contain certain levels of one of hundreds of listed chemicals determined to…
On December 6 2017, the California Office of Environmental Health Hazard Assessment (OEHHA) issued a notice indicating the approval of amendments to Proposition 65’s “clear and reasonable warnings” regulations. OEHHA issued these amendments to clarify and correct certain sections of the significant new regulations going into effect August 30, 2018 that will change how parties in the supply chain for consumer products must warn their customers. Under the Proposition 65 regulations, a manufacturer, distributor, or retailer…
On December 6 2017, the California Office of Environmental Health Hazard Assessment (OEHHA) issued a notice indicating the approval of amendments to Proposition 65’s “clear and reasonable warnings” regulations. OEHHA issued these amendments to clarify and correct certain sections of the significant new regulations going into effect August 30, 2018 that will change how parties in the supply chain for consumer products must warn their customers. Under the Proposition 65 regulations, a manufacturer, distributor, or…
On December 4, 2017, the Wisconsin Department of Natural Resources (DNR) amended its National Ambient Air Quality Standards (NAAQS) for fine particulate matter (PM2.5). The rule reduces the primary annual standard for PM2.5 from 15.0 to 12.0 micrograms per cubic meter (µg/m3). DNR was required to promulgate this rule to be consistent with the U.S. EPA NAAQS for PM2.5, published in January, 2013. The DNR rule is scheduled to be effective January 1, 2018, and…
The month of August, 2017 has seen three distinct developments that may significantly impact management of “Coal Combustion Residuals,” or “CCR,” which include bottom ash, fly ash, boiler slag, and flue gas desulfurization materials generated from burning coal at steam powered electricity plants. Although one of these developments may provide a degree of regulatory relief, the other two may preserve or even strengthen existing regulatory requirements.…
On December 21, 2016, the U.S. Environmental Protection Agency finalized amendments to its Risk Management Program (RMP). The EPA Administrator, Gina McCarthy, signed the final rule but it has not yet been published in the Federal Register. Background The Accidental Release Prevention regulations under section 112(r) of the Clean Air Act, also called the Risk Management Program regulations, require covered facilities to develop and implement a risk management program and coordinate with state and local…
The United States Securities and Exchange Commission (“SEC”) is reviewing sustainability. On April 13, 2016 the SEC issued a “Concept Release” seeking public comments on 340 topics relating to business and financial disclosure requirements for publicly-traded companies under Regulation S-K. See 81 Fed. Reg. 23916 (April 22, 2016) (“CR”). Several topics addressed the disclosure of company information relating to sustainability and public policy issues. Such issues, including climate change, resource scarcity, corporate social responsibility (“CSR”),…