Although many agencies and officials in the Trump administration downplay or deny human contributions to climate change, a major new government report accepts that proposition, and documents its extent. On November 5, the U.S. Global Change Research Program published its Climate Science Special Report, which will serve as Volume 1 of the U.S. Fourth National Climate Assessment (NCA4). The Program is a group of 13 federal agencies with relevant authority and expertise, with the development of the NCA4 overseen by the National Oceanic and Atmospheric Administration (NOAA). The Program was established by the Global Change Research Act (GCRA) of 1990, to “assist the Nation and the world to understand, assess, predict, and respond to human-induced and natural processes of global change.” As summarized in the Executive Summary to the Report:Read More
Audit, Compliance and Risk Blog
In March 2017, President Trump issued an executive order (EO) “Promoting Energy Independence and Economic Growth,” which packaged a set of repeals and re-directions to move US federal policies firmly away from climate change and toward domestic fossil fuels. (I wrote about it here). Among its many provisions, the EO directs federal agencies, including the Environmental Protection Agency (EPA), to “review all existing regulations, orders, guidance documents, policies, and any other similar agency actions (collectively, “agency actions”) that potentially burden the development or use of domestically produced energy resources…” The EO also orders EPA to review several specific rules.Read More
The Federal Trade Commission’s guidelines for testimonials and endorsements require disclosure of any payment or benefit that endorsers receive for their endorsements.Read More
As I’ve discussed in recent blogs, President Trump’s executive agencies, including the Environmental Protection Agency (EPA), are dramatically reducing federal attention to “climate change.” Obama-era initiatives are being terminated or reversed, and planning and communication are being reduced or eliminated. (For example, I noted in my recent discussion of EPA’s draft Strategic Plan, here, that the draft does not mention the phrases “climate change” or “greenhouse gas” even once).Read More
Although Environmental Health and Safety (EH&S) requirements target hundreds of micro-organisms (primarily viruses and bacteria), important hazards remain unregulated. Many await definitive scientific conclusions, but others need testing and control methodologies that would allow requirements to be designed and administered, sufficient regulator and regulated entity resources, and/or high enough political priorities. Until recently, one of these unregulated pathogens has been the legionella bacterium, first identified in 1976 as the cause of “Legionnaire’s disease,” which appears as a form of pneumonia.Read More
In October 2016, EPA produced a White Paper announcing the “urgent need” for revisions, describing key issues and possible revisions, and projecting to propose extensive LCR revisions during 2017. However, since President Trump assumed office, EPA’s priorities are shifting and its resources are being reduced (for example, I wrote about EPA’s Back-to-Basics Agenda here). Most recently, EPA’s formal agency-wide regulatory agenda now postpones the issuance of a Notice of Proposed Rulemaking (NPRM) until January 2018 and a final rule until June 2019. While we await action, it’s worth considering how PWSs can reduce lead exposures, particularly since building owners and employers might consider improvements to plumbing and fixtures that could improve workplace water quality.
What Does LCR Require?
The LCR divides PWSs into three groups based on the numbers of customers served, and assigns tailored responsibilities for testing, corrosion control, source water treatment, and pipe replacement. The three groups are:Read More
The Paris Agreement anticipated that sub-national governments and private organizations would contribute to global progress, by meeting and often exceeding national requirements (I wrote about formal United Nations programmatic expectations here).
One of the non-governmental efforts is the Science Based Targets Initiative, through which individual companies can set GHG-reduction goals. At latest report, over 300 companies participate.
What is the Science Based Targets Initiative?
The Initiative is a multi-sector collaboration among the following international organizations: CDP (formerly called the Carbon Disclosure Project), World Resources Institute (WRI), the World Wide Fund for Nature (WWF; formerly World Wildlife Fund), and the United Nations Global Compact (UNGC). Participation in the Initiative is also identified as one of the commitments under the We Mean Business Coalition, which is another international business initiative. The Initiative defines “science-based targets” by reference to the Initiative’s effort to support the 2o C target (which the Initiative refers to as the “2°C pathway”):Read More
EPA Administrator Scott Pruitt has, by word and individual action, been moving the Environmental Protection Agency (EPA) away from President Obama’s aggressive agenda and toward President Trump’s preference for reduced activity. These have included a less-regulatory “Back-to-Basics Agenda,” which I described here. Now the agency is proposing to formalize these priorities in its strategic plan for the next four fiscal years, 2018-2022.Read More
In a recent decision, Canadian Union of Postal Workers v. Canada Post Corporation, the Federal Court of Appeal reversed an earlier Federal Court endorsement of an appeals officer’s decision to limit the definition of “workplace” for the purposes of inspection under Part II of the Canada Labour Code to workplaces where the employer exercises control.Read More
One of new Environmental Protection Agency (EPA) administrator Scott Pruitt’s many initiatives has been to change his agency’s approaches to cleanups under the national Superfund law. He announced several basic policy changes in May, and convened a Superfund Task Force to develop detailed recommendations. The task force issued its report late in July, offering 42 recommendations. These are summarized below.Read More