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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EPA provides battery energy storage system safety and response guidance
Posted by Jon Elliott on Fri, Sep 26, 2025
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
EPA narrows criminal enforcement to follow administration priorities
Posted by Jon Elliott on Fri, Sep 05, 2025
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).
Read MoreTags: 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
Administration proposes zero budget for Chemical Safety Board
Posted by Jon Elliott on Fri, Aug 08, 2025
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
Here’s how to think about contractor selection, onboarding, and safety audits in a way that supports your organization without overstepping boundaries.
Tags: EHS, workplace safety, OHS, EHSCompliance, Risk Management, Safety Audits, Contractor Safety, EHS Compliance, Prequalification
California proposes regulations for phase-out of non-recyclable single-use plastics
Posted by Jon Elliott on Fri, Jul 25, 2025
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
Trump Administration proposes limited cuts in OSHA budget
Posted by Jon Elliott on Fri, Jul 18, 2025
On May 2, the Trump Administration issued its budget proposal for federal Fiscal Year (FY) 2026 (October 1, 2025 through September 30, 2026). The administration proposes a $582,381,000 budget for the Occupational Safety and Health Administration (OSHA), which would be a 7.9% ($49,928,000) decrease from OSHA’s adopted 2025 budget of $632.3 million (the Biden Administration had proposed $655.5 million; I wrote about it HERE). The remainder of this note summarizes the Administration proposal.
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Tags: OSHA, workplace safety, Trump, Trump Administration, Workplace Safety Guidelines, Regulatory Compliance, Safety Standards, FY 2026 Budget, Federal Budget Proposal, Occupational Safety
The Trump Administration has issued its budget proposal for federal Fiscal Year (FY) 2026 (October 1, 2025 through September 30, 2026), including a 54% cut in the Environmental Protection Agency (EPA) budget, from $9.1 billion in FY 2025, to $4.16 billion for FY 2026. Many of the cuts apply to grant programs, and the proposal would cut staffing by 9%, from 14,130 full-time-equivalent employees (FTE) to 12,856. Readers should note that these cuts are comparable to those proposed by President Trump during his first term; EPA’s actual annual budget depends on that adopted by Congress (or a continuing resolution in lieu of an adopted budget). The remainder of this note summarizes EPA’s proposed FY2026 budget, including proposed reductions, drawn from EPA’s “Budget in Brief” (68 pages) and “Justification of Appropriation Estimates” (736 pages).
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Tags: EPA, RCRA, tsca, Clean Air Act, Environmental Policy, Climate, EPA Regulations, EPA Standards, Trump, Trump Administration, Climate Reporting