Pamela Elkow

I’m a partner in Robinson+Cole’s Environmental and Utilities Practice Group. I’ve been practicing law with a focus on environmental and health and safety issues for over 20 years. I work with a wide variety of clients, ranging from Fortune 50 companies and large institutions such as universities, to small, closely-held businesses and municipalities. Here’s the link to my full and official bio.

Many of my clients are manufacturers with ongoing environmental, health and safety issues associated with their business operations. I advise them on day-to-day compliance and permitting issues, work with them to compile or review health and safety manuals, and defend them against enforcement actions resulting from allegations of violations of environmental or occupational health and safety regulations. I see myself as part of the client team – my task is not just to raise issues and liabilities, but to work with the client to come up with cost-effective, practical solutions to those issues, and to minimize liabilities. To do that, I need to know the business – what do they make and how do they make it? I’m comfortable talking to management, or the folks on the floor. Getting to know the business and how the client does what they do – that’s what drives me to work with manufacturers. I’m never happier than when learning how something works, how something is made, or just something new.

Latest Articles

A good way to get a sense of OSHA’s priorities and focus is to look at the citations it’s recently issued. So this post will highlight just a few of the recent enforcement actions by OSHA Region 1 (MA, CT, VT, NH and ME). Bantam, Conn. – U.S. Chutes Corp. was cited for nine repeated and 15 serious violations, with a proposed penalty of $94,248. U.S. Chutes is a manufacturer of galvanized laundry chutes. The…
Even if you’re well-versed in environmental statutes, one you might not spend a lot of time thinking about is the Toxic Substances Control Act, or TSCA.  That’s because, with a few notable exceptions (PCBs being a good example), TSCA currently focuses on regulating new chemicals as they are introduced into commerce, or on significant new uses for existing chemicals, issues that are not generally of concern to manufacturers.   That may soon change. TSCA has not…
(Many thanks to my colleague and source of all info air related, Brian Freeman, who wrote today’s post.) Malfunctions happen, even at a well-managed facility.  When they happen, they can cause a facility to deviate from emission limits or other standards regarding (among other things) hazardous air pollutants.  Furthermore, through several court rulings and EPA responses, former “safe harbors” for malfunctions under hazardous air pollutant rules have been removed, and a compliance deviation due…
Matt set a pretty high bar last week, summarizing his thoughts for what could be a tumultuous 2015 on the labor and employment front.  Now, it’s my turn to provide some thoughts for 2015 the EHS front.  I’m not sure I’d call all of these predictions, since we know that they’re out there – more like “stuff to watch out for.” 1. New OSHA reporting requirements take effect. As we discussed back in September, OSHA…
We wanted to use this last post of the year to wish all who of you who read Manufacturing Law Blog a wonderful holiday season, and a very happy, safe and healthy New Year! We will be posting in early January our collective thoughts on the issues that we think will be of interest to manufacturers in 2015.  We see good things on the horizon – the economy seems to picking up, which likely means…
Obviously, our blog focuses on issues that affect manufacturers.  Specifically, my posts deal with environmental or health and safety issues manufacturers face. Sometimes, though, it’s good to step back and remember that manufacturers are also companies that occupy buildings and have employees, and there are environmental or health and safety issues that just go along with occupying a building and having employees.  Here are just a few…. Winter and snow removal. Here in Connecticut, we’ve…
“To compete in today’s global marketplace, manufacturers need to be smart, innovative, and sustainable.” That’s the first thing you read on the federal government’s E3 webpage – E3 stands for “Economy – Energy – Environment.” Manufacturers are an adaptable bunch, or they don’t stay in business for very long. Today, with materials of all sorts increasing in costs or impact, manufacturers who want to adapt to be more energy efficient, sustainable or “green” may have…
Everyone knows that the permissible exposure limits or PELs set forth in various OSHA standards are pretty old (most have not been updated since 1971), and that we’ve learned a lot about chemical exposure and human health in the years since those PELs were originally published.  OSHA knows it, too.  Furthermore, of the thousands of chemicals in the workplace, OSHA has adopted PELs for less than 500 of these chemicals.  OSHA is looking for guidance…
OSHA just announced updates to its reporting and recordkeeping requirements for injuries and illnesses, found at 29 CFR 1904. The updates include changes to who is required to comply with the recordkeeping rules, and expands the work-related injuries that must be reported. Recordkeeping The list of industries exempt from routine recordkeeping (think OSHA 300 log) has been updated, and is now based on the North American Industry Classification System (NAICS); the existing rule was…
While spring is typically the time of year we think of for cleaning, I find fall a good time to do it. I probably never got over the feeling of new beginnings that come with fall and school starting. So, as I was cleaning my garage this past weekend (which truth be told is really a four-season job), and thinking about the fact that I was my turn to write, I started contemplating what a…