Shannon S. Broome

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Ho Ho Ho! Happy Hanukkah! Happy New Year! And so it goes this time of year, with family and friends gathering for the holidays to share a hot toddy and some good cheer! As October and November gently glide by, Heading into December for cookies and pie, But lo, the environmental lawyer sits wearily writing at the computer, throwing fits. What will the court or the EPA say Will be due around Christmas, Hanukkah, Kwanzaa…
The effects of the regulatory reform initiatives of the Trump Administration are beginning to be felt at the Occupational Safety and Health Administration (OSHA) with the formal action by OSHA to finalize withdrawal of the “Volks Rule” regulation. On May 3, 2017, in response to a CRA resolution of disapproval, OSHA published a final rule removing amendments to OSHA’s recordkeeping regulations from the Code of Federal Regulations.…
Just before Christmas, the U.S. Environmental Protection Agency (EPA) released controversial regulations, titled Accidental Release Prevention Requirements: Risk Management Programs under the Clean Air Act; Prepublication Final Rule, that EPA states will “modernize” the Clean Air Act Section 112(r)(7) Risk Management Program (RMP) regulations. These 1990s-era regulations, covering about 12,500 facilities across the country, require that facilities storing certain amounts of specified chemicals develop risk management plans to prevent the accidental release of those substances…