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As President Trump begins his second term, companies should prepare for significant shifts in environmental health and safety (EHS) regulations and enforcement. This alert outlines key anticipated changes, including leadership transitions, potential staffing impacts, using executive orders to change agency priorities, and regulatory rollbacks.

1. Leadership Changes

Department of Labor (DOL): The DOL is

On July 30, 2024, The United States Court of Appeals for the District of Columbia Circuit temporarily halted litigation over the U.S. Environmental Protection Agency’s (EPA) updated Risk Management Program (RMP) rule and granted a four-month abeyance. The final RMP rule was published on March 22, 2024.

The order granting the abeyance allows EPA time

On July 2, 2024, the Occupational Safety and Health Administration (OSHA) released the official text of its Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings proposed standard. OSHA has been developing this standard since 2021, which will likely be finalized later this year.

The standard includes general mandates for all covered employers

The Washington Department of Labor and Industries (L&I) adopted CR-103, creating a new Part B to chapter 296-67 WAC, on December 27, 2023.  Specifically applicable to petroleum refineries, Part B includes and updates existing PSM requirements as well as introduces several new requirements, some of which are expected to be onerous for refiners to

The Occupational Safety and Health Administration (“OSHA”) has recently submitted to the White House Office of Management and Budget (“OMB”) a final rule to update its Hazard Communication Standard (“HazCom”), which regulates the classification and labeling of hazardous chemicals in the workplace. The rule aims to align the HazCom with the latest version of the

On September 30, 2023, California Governor Gavin Newsom signed SB-553 into law. SB-553 is the nation’s first workplace violence prevention law.  The law adds a new section 6401.9 to the California Labor Code, which will be implemented by Cal/OSHA.  The new law requires that employers an effective plan aimed at preventing workplace violence in place

The US Environmental Protection Agency (EPA) recently proposed a significant addition to its Renewable Fuel Standards (RFS) program—the renewable electricity RIN (eRIN). The eRIN is a new kind of renewable identification number (RIN) obligated parties could obtain to meet their renewable volume obligations and comply with the RFS program.

Under the current RFS program, obligated

The Occupational Safety and Health Administration (OSHA) recently released two memos instructing enforcement officers on “instance-by-instance” citations and de-grouping violations to deter infractions. 

OSHA’s prior policy on instance-by-instance citations, published in 1990, applied just to willful citations. The new guidance identifies several scenarios where such citations may be issued, including high-gravity serious violations specific to falls, trenching