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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
News:
The EPA has published a 12-page paper explaining how it is meeting a Clean Air Act (CAA) requirement that it conduct periodic reviews of certain aspects of the Renewable Fuel Standard (RFS).
Backing up his commitment to improve the federal Superfund program, EPA Administrator Scott Pruitt has issued a list of 21 Superfund sites that he has “targeted for immediate and intense attention.”
Twenty-six oil and natural gas (O&G) companies have introduced a new voluntary program “focused initially on reducing methane and volatile organic compound (VOC) emissions.” 
President Donald Trump’s August 15, 2017, Executive Order (EO) on improving the federal environmental review process may set the stage for changes to regulations affecting how states participate meaningfully in such reviews.
Fifteen attorneys general (AGs) have filed a complaint with the U.S. District Court for the Northern District of California, requesting that the court order the EPA to meet its Clean Air Act (CAA) nondiscretionary obligation to declare which areas of the country are in nonattainment with the Agency’s 2015 National Ambient Air Quality Standards (NAAQS) for ozone.
In its 2017 Update of its Regulatory Agenda, the EPA states that it is considering a proposal to add hazardous waste aerosol cans to those universal wastes regulated under 40 CFR 273.
Stating that existing programs are successfully assuring that financial instruments are available to cover adequate response to risks associated with the hard-rock mining sector, the EPA has decided not to exercise its authority under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) to require that the sector acquire additional financial assurance.
On Monday, President Donald Trump issued two proclamations “modifying” the boundaries of two national monuments in Utah: Bears Ears National Monument (BENM) and Grand Staircase-Escalante National Monument (GSENM).

After several extensions of the effective date, EPA's revisions to the Certification of Pesticide Applicators rule will take effect on May 22, 2018. With less than 6 months left to prepare, this article discusses what you need to know about how the changes will affect you and any pesticide applicators that you manage or employ.

On Thursday, November 30, 2017, the EPA announced the final renewable fuel standards (RFS) for 2018 total renewable fuels and 2019 for biodiesel.
During a nomination hearing, Kathleen Harnett White, President Donald Trump’s choice to lead the White House Council on Environmental Quality (CEQ) was asked to explain multiple past statements that troubled Democrats on the Senate Environment and Public Works Committee (EPW).
Oil and gas (O&G) companies may get an opportunity to expand development operations in Idaho if the EPA finalizes a proposal to take over the state’s Underground Injection Control (UIC) Program for Class II wells.
The EPA announced that it has determined that a revision of the current small business size standards under a section of the Toxic Substances Control Act (TSCA) is warranted.
White Papers:
If you run an operation that generates pollution—or if you are responsible for reducing pollution that comes from somewhere else, as with public wastewater treatment plants or public drinking water systems—you likely use or will at some point need to obtain the services of an environmental testing lab.
According to a report from the Government Accountability Office (GAO), the Department of Defense (DOD) has produced mixed results at managing drinking water at its facilities.
Guidance Documents:
Display this BLR poster where hazardous waste is accumulated or stored at your facility so that your employees can review whether your containers of hazardous waste are in compliance with the RCRA regulations.
This EPA guidance document helps drinking water and wastewater utilities understand the key concepts and basic procedures of responding to contamination threats and incidents.
This table created by the EPA sets forth the maximum contaminant levels (MCLs), the common sources of contamination, the potential health effects, and the public goals for each of the contaminants it regulates under the National Primary Drinking Water Regulations.
Use this chart created by the EPA to compare the existing Certification of Pesticide Applicators rule to the new rule taking effect May 22, 2018.
Forms:
This document contains sample policies that outline security rules and regulations for a variety of workplaces and provides tips and considerations for developing an effective security policy.
Updated Documents
Forms:
This document contains sample policies that outline security rules and regulations for a variety of workplaces and provides tips and considerations for developing an effective security policy.
Guidance Documents:
Display this BLR poster where hazardous waste is accumulated or stored at your facility so that your employees can review whether your containers of hazardous waste are in compliance with the RCRA regulations.
This EPA guidance document helps drinking water and wastewater utilities understand the key concepts and basic procedures of responding to contamination threats and incidents.
This table created by the EPA sets forth the maximum contaminant levels (MCLs), the common sources of contamination, the potential health effects, and the public goals for each of the contaminants it regulates under the National Primary Drinking Water Regulations.
Use this chart created by the EPA to compare the existing Certification of Pesticide Applicators rule to the new rule taking effect May 22, 2018.
This EPA brochure describes how self-injectors can dispose of their used needles and lancets safely.
This EPA presentation is an overview of the major provisions of the proposed rule.
This guidance document from the Food and Drug Administration reviews how to safely dispose of needles and other sharps used to manage medical conditions.
Regulatory Analysis:
RCRA requires hazardous waste large quantity generators (LQGs) and treatment, storage, and disposal facilities (TSDFs) to report every 2 years on the quantities, type, and management method of hazardous wastes generated on-site and hazardous wastes received from off-site sources. Referred to by the EPA as the Hazardous Waste Report (EPA Form 8700-13 A/B), and by those in the environmental management field as the Biennial Report, the report must be submitted by March 1 of every even-numbered year with information of the facility's hazardous waste activities during the previous odd-numbered calendar year. Some states require generators and TSDFs to submit an annual hazardous waste report in addition to, or in lieu of, the federal biennial report. Many of the state regulatory agencies will use these annual reports to complete a facility's federal biennial report that the agency then sends to the EPA in order to fulfill the federal requirement.
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