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On December 11, 2018, U.S. EPA Acting Administrator Andrew Wheeler signed a new hazardous waste pharmaceutical rule. The final rule retains a proposed requirement, opposed by industry, that prescription pharmaceuticals sent from health care facilities to reverse distributors first be considered “disposed of,” regulated as solid waste and evaluated for hazardous classification at the health care facility. This rule will impose significant new obligations on health care providers, including pharmacies and long-term care providers,…
A coalition of states has opened a new front in the ongoing battles between the Trump Administration’s efforts to streamline regulations applicable to industry and the interests favoring additional regulation.  In response to the United States Environmental Protection Agency’s (“U.S. EPA’s”) recent announcement that the agency will ease greenhouse gas (“GHG”) emission standards applicable to light-duty vehicles, a group of states have gone to court to oppose that change.…
The Trump Administration has taken steps to roll back Greenhouse Gas (GHG) emissions standards applicable to most automobiles in the United States.  On April 2nd Environmental Protection Agency Administrator Scott Pruitt announced plans to roll back an Obama Administration determination that left the Midterm Evaluation standards in place for the 2022-2025 GHG emission limits for light-duty vehicles. The Midterm Evaluation standards, finalized in 2012, had imposed heightened requirements for fuel efficiency in automobiles.…
In a major change in air permitting policy, on January 25, 2018 U.S. EPA reversed its longstanding “once in, always in” policy governing what sources are subject to major source regulations for the emissions of  air toxics under Section 112 of the Clean Air Act.  Under a 1995 policy memorandum issued by the agency, sources that had the potential to emit above the major source thresholds at the time a standard applied to a particular…