On September 2, 2025, the California Air Resources Board (ARB) posted a draft checklist with information to help targeted “covered entities” comply with requirements to provide “Climate Related Financial Risk Disclosure.” These Disclosures are required beginning January 1, 2026, in compliance with state legislation (SB 261 (Stern)) enacted in 2023 (which I wrote about HERE), and amended in 2024 (SB 219 (Wiener); I wrote about it HERE). The remainder of this note summarizes SB 261 and ARB’s draft checklist.
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sustainability,
ARB,
compliance,
Environmental Regulations,
Corporate Sustainability,
Climate Disclosure,
ESG Reporting,
SB261,
CARB,
Corporate Risk
On September 16, 2025, the US Environmental Protection Agency (EPA) published a proposal to eliminate the vast majority of its longstanding Greenhouse Gas Reporting Program (GHGRP), which requires thousands of facilities and organizations to report annual emissions of greenhouse gases (GHGs) (40 CFR part 98). (I’ve written about this program over the years, most recently when EPA issued massive revisions in April 2024 (see HERE). The remainder of this note briefly summarizes EPA’s latest interpretation and identifies the small portion EPA proposes to retain, and the existing GHGRP.
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Tags:
EPA,
Greenhouse Gas,
Clean Air Act,
Climate,
Environmental Compliance,
EPA Regulations,
EPA Standards,
GHG Reporting,
EPA enforcement,
Climate Disclosure,
Climate Risk,
Air Quality
On August 21, the US Environmental Protection Agency (EPA) posted updated guidance for battery energy storage system (BESS) installation and incident response. EPA has added a 3-page Fact Sheet, “Battery Energy Storage Systems: Main Considerations for Safe Installation and Incident Response” to its online compilation of information for “Sustainable Management of Electronics and Batteries.” EPA notes that BESS operations help stabilize electrical grids by providing steady power flow, particularly where there may be interruptions in grid power or fluctuations in production from renewable energy sources. However, EPA also notes that lithium battery fires at some installations (notably at commercial facilities in San Diego and Moss Landing, California) have raised safety concerns in many communities. EPA intends its new guidance to help address these concerns; the remainder of this note summarizes EPA’s new guidance.
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Tags:
EHS,
EPA,
sustainability,
Clean Energy,
Fire Safety,
Environmental Health and Safety,
Fire Risk Management,
Risk Management,
Battery Energy Storage
The US federal Occupational Safety and Health Administration (OSHA) administers a General Materials Handling Standard (29 CFR 1910.176) that provides general requirements to ensure safe management of materials, including provisions for storage, loading and unloading, and other operational hazards.The remainder of this note summarizes these longstanding requirements.
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Tags:
OSHA,
workplace safety,
Health and Safety Compliance,
Occupational Health,
Safety Regulations,
Health and Safety,
Occupational Safety,
Materials Handling
The US environmental Protection Agency (EPA) continues to narrow its enforcement focus in order to follow Trump administration priorities. I recently wrote about EPA’s May 2025 statement of new enforcement policies (I wrote about that memo HERE). Now, EPA has announced further changes, to align its activities with the President’s Executive Order “Fighting Overcriminalization in Federal Regulations” (EO 14294). The remainder of this note summarizes these changes.
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Tags:
EPA,
Environmental Policy,
Environmental Compliance,
EPA Regulations,
EPA Standards,
Trump Administration,
Environmental Health and Safety,
Environmental Protection Agency,
EPA enforcement
On July 1, the US federal Occupational Safety and Health Administration (OSHA) published proposals to revise or repeal more than two dozen of its occupational safety and health standards. OSHA justifies many of these changes as ways to reduce duplicative requirements or increase employers’ flexibility. The remainder of this note identifies these proposals, identifying code sections within OSHA’s General Industry standards (most in 29 CFR 1910 (most proposals also apply to analogous Construction and Maritime standards).
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Tags:
Health & Safety,
OSHA,
Compliance Safety,
RegulatoryUpdates,
Workplace Safety Guidelines,
Risk Management,
Safety Standards,
EHS Compliance
The US federal Occupational Safety and Health Administration (OSHA) has revised portions of its national enforcement policies, reducing penalties for employers that take prompt action to correct identified violations, and raising the ceiling for special small business penalty reductions from employers with 10 or fewer employees to those with 25 or fewer employees. These revisions appear in Chapter 6 (Penalties and Debt Collection) of OSHA’s Field Operations Manual (FOM). The remainder of this note discusses these revisions.
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Tags:
OSHA,
Occupational Health,
Worker Safety,
Workplace Safety Guidelines,
Safety Standards,
Occupational Safety,
Field Operations Manual,
FOM
Many of the Trump administration’s recent budget requests have proposed reduction in funding for environmental, health and safety (EH&S) agencies (For example I wrote about the environmental Protection Agency (HERE and Occupational Safety and Health Administration HERE ). Most drastically, the administration has proposed ZERO funding for the federal Chemical Safety and Hazard Investigation Board – which usually refers to itself as the Chemical Safety Board or CSB. CSB conducts independent investigations of major chemical accidents, issues accident-specific findings, offers specific or general recommendations for improved chemical handling and regulation, and has enacted a “Chemical Incident Reporting Rule.” (I wrote about the Rule HERE, and compliance guidance HERE). The remainder of this note summarizes CSB’s latest guidance.
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Tags:
OSHA,
Environmental,
EHS,
EPA,
CSB,
Chemical Safety Board,
Trump Administration,
EHS Compliance,
Incident Reporting,
Accidental Release Prevention,
Process Safety Management,
chemical incident investigations
When managing contractor safety, many hiring clients focus heavily on pre-qualification — confirming that a contractor has the right certifications, training, insurance, and safety programs in place. But pre-qualification is only the starting point. Once you’ve selected a contractor, the real work begins: onboarding, oversight and, in many cases, auditing.
Auditing your contractors can be one of the most effective ways to protect your people, manage liability, and ensure that safety commitments on paper are translating into real action on-site.
Here’s how to think about contractor selection, onboarding, and safety audits in a way that supports your organization without overstepping boundaries.
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Tags:
EHS,
workplace safety,
OHS,
EHSCompliance,
Risk Management,
Safety Audits,
Contractor Safety,
EHS Compliance,
Prequalification
The California Department of Resources Recycling and Recovery (CalRecycle) has published a revised set of proposed regulations to implement 2022’s Senate Bill (SB) 54, the “Plastic Pollution Prevention and Packaging Producer Responsibility Act.” (I wrote about the legislation HERE). The Act phases in a ban on non-recyclable single-use plastics by 2032, and requires that threshold proportions of single-use items sold as “recyclable” will actually be recycled. Its implementation will make use of “extended producer responsibility” (EPR) mechanism similar to those used in California and elsewhere for other enhanced recycling programs (I’ve written about these before, most recently HERE). The remainder of this note discusses the proposed regulations and SB 54’s provisions.
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Tags:
sustainability,
California,
California Environmental Law,
Plastic Waste,
Sustainability Reporting,
Sustainability Strategy,
SB54,
California Regulations,
CalRecycle,
Plastic Pollution
