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Regulatory Analysis
We are continually updating our state and national regulatory analysis to help you keep up-to-date with the changing regs. See the updated section on the what's new page to find all of the topics.
Recent Regulatory Activity
New Documents
With the goal of expediting resolution of objections to permits issued by the EPA under major environmental statutes, the Agency is proposing amendments to regulations governing its Environmental Appeals Board.
The U.S. Environmental Protection Agency (EPA) finalized its reconsideration of Risk Management Program provisions that were amended in 2017. EPA opted to rescind some of the amended provisions for various reasons, and retain or modify other provisions.
Sixty days after its publication in the Federal Register, a final EPA rule will formally add hazardous waste aerosol cans to the federal Universal Waste program.
Many stakeholders are following—or should be following—the federal government’s plans to address the impact of per- and polyfluoroalkyl substances (PFAS) on human health and the environment.
The EPA is proposing to add two questions to the list of questions chemical manufacturers (which include importers) and processors must answer to substantiate claims that the identities of chemicals must be protected from public disclosure.
The EPA regulates how much the coal-fired electricity sector must do and how much it must spend to dispose of and manage wastes caused by coal combustion. In 2015, the Obama EPA issued two major rules affecting the obligations of coal-fired power plants, but both rules were challenged in court.
The EPA recently released a draft risk evaluation for the solvent methylene chloride.
White Papers:
The EPA’s Office of Land and Emergency Management recently issued a memo to focus the attention of the Agency’s regional offices and stakeholders on the EPA's regulations for reverse distribution of prescription pharmaceuticals and its policy on reverse logistics for nonprescription pharmaceuticals and other retail items.
Is chemotherapy waste that is trace or RCRA Empty considered hazardous waste?
Do you have to store hazardous waste that is in satellite and central accumulation in DOT containers or can they be stored in any container and transported to DOT required containers before transport?
Updated Documents
Guidance Documents:
This EPA memorandum provides agency staff with general guidance on the “common elements” of the statutory landowner liability protections for Bona Fide Prospective Purchasers (BFPPs), Contiguous Property Owners (CPOs), and Innocent Landowners (ILOs) to assist them in exercising their enforcement discretion and to provide general information to landowners, developers, lenders, investors, or other third-party stakeholders who may wish to become involved with impacted properties. This memorandum supersedes the 2003 Interim Guide, “Common Elements” Guidance Reference Sheet (March 2003), and Superfund Interest Reasonable Steps Comfort/Status Letter on this topic.
Regulatory Analysis:
The RCRA used oil management standards found at 40 CFR 279 serve as a road map to guide used oil handlers (generators, transporters, burners, marketers, processors, and rerefiners) through the various storage, recordkeeping, and cleanup procedures that work together to ensure that used oil is handled safely.
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