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HTMLRegistration of Foreign Facilities Producing Food and Food Packaging Sold in Korea
Yun Chen, David J. Ettinger, Wilfred Feng, Eric Gu, Mark Thompson; Keller and Heckman LLP;
Legal Alert/Article
May 30, 2016, previously published on April 27, 2016
Only a few months remain before the August 3, 2016 deadline for Korean registration of foreign food and food packaging manufacturing facilities. Registration is required for all facilities producing food, food additives, food packaging as well as components thereof, including functional health...

 

HTMLThe Cole-Bishop Amendment to the Agricultural Appropriations Bill Amending the Grandfather Date for "Deemed" Tobacco Products Passes House Committee - What Next?
Azim Chowdhury, Samantha L. Dietle; Keller and Heckman LLP;
Legal Alert/Article
May 26, 2016, previously published on April 29, 2016
On April 19, 2016, the House Appropriations Committee voted to include a bipartisan amendment, sponsored by Rep. Tom Cole (R - OK) and Rep. Sanford Bishop (D - GA), to the 2017 fiscal year Agricultural Appropriations bill that would amend the February 15, 2007 "grandfather date" for...

 

HTMLNew TSCA Chemical Safety Advisory Committee (CSAC) Now Active
Martha E. Marrapese; Keller and Heckman LLP;
Legal Alert/Article
May 26, 2016, previously published on May 2, 2016
EPA has now activated the TSCA Chemical Safety Advisory Committee (CSAC) that it announced it would establish in June 2015. The CSAC will provide independent scientific advice and recommendations on the scientific basis for the agency’s risk assessments, methodologies, pollution prevention...

 

HTMLUpdating The Biotechnology Mission For The Bioeconomy
Martha E. Marrapese; Keller and Heckman LLP;
Legal Alert/Article
April 14, 2016, previously published on March 15, 2016
What is the bioeconomy? The February 2016 Federal Activities Report on the Bioeconomy describes it as a loose-knit, diverse group of commercial activities with their common frame of reference being the deployment of renewable resources — plants, trees and vegetation — to make useful...

 

HTMLOSHA's New Rule on Crystalline Silica Goes into Effect
David G. Sarvadi, Cressinda D. Schlag; Keller and Heckman LLP;
Legal Alert/Article
April 14, 2016, previously published on March 28, 2016
On Friday, March 25, 2016, the Occupational Safety and Health Administration (OSHA) published a final rule reducing the permissible exposure limit (PEL) to respirable crystalline silica (RCS), reducing the PEL to 50 micrograms of respirable crystalline silica per cubic meter of air (µg/m3) averaged...

 

Adobe PDFThe Downfall of the Paralyzed Veterans Doctrine Grants Federal Agencies a "Dangerous Permission Slip for the Arrogation of Power" and Exposes the Regulated Community to Potentially Fatal Doses of Regulation Run Amok
Lawrence P. Halprin; Keller and Heckman LLP;
Legal Alert/Article
March 30, 2016, previously published on March 8, 2016
The Downfall of the Paralyzed Veterans Doctrine Grants Federal Agencies a “Dangerous Permission Slip for the Arrogation of Power” and  Exposes the Regulated Community to  Potentially Fatal Doses of Regulation Run Amok (a/k/a The Triple Whammy of Perez, Auer and Whitman) In the Spring of...

 

Adobe PDFA Practical Understanding of the Polymer Exemption
Thomas C. Berger, Rhys G. Daniels, Matthew B. Harney, Adrienne M. Timmel; Keller and Heckman LLP;
Legal Alert/Article
March 30, 2016, previously published on March 14, 2016
The polymer exemption at 40 C.F.R. § 723.250 exempts qualifying polymers from the premanufacture notification requirements of section 5 of the Toxic Substances Control Act (TSCA), (40 C.F.R. § 720). To implement the exemption persons need only internally and in writing certify compliance...

 

HTMLWhat's Next for Incentive Programs under OSHA's Draft Safety and Health Program Management Guidelines?
Lawrence P. Halprin, Cressinda D. Schlag; Keller and Heckman LLP;
Legal Alert/Article
March 30, 2016, previously published on March 14, 2016
On Thursday, March 10, 2016, OSHA held a public meeting to discuss its draft Safety and Health Program Management Guidelines (Guidelines). Most of the meeting was devoted to a discussion of the written comments received in the 90-day comment period, with a focus on areas that raised stakeholder...

 

HTMLNew Hazard Alert on Tank Gauging and Sampling for the Oil and Gas Industry
Herbert Estreicher, Lawrence P. Halprin, Martha E. Marrapese, Manesh K. Rath, David G. Sarvadi; Keller and Heckman LLP;
Legal Alert/Article
March 23, 2016, previously published on February 24, 2016
On February 12, 2016, the Occupational Safety and Health Administration (OSHA) and the National Institute for Occupational Safety and Health (NIOSH) jointly published a hazard alert for the Oil and Gas Industry on tank gauging and sampling. The alert identifies common hazards posed by manual tank...

 

HTMLComparison of House and Senate Proposals on Preemption
Keller Heckman LLP;
Legal Alert/Article
March 16, 2016, previously published on March 9, 2016
In the House-passed legislation, the preemption triggering event is when EPA issues § 6 rule or determines that substance does not present an unreasonable risk. Preemption is absolute at that point, in that it applies to new or existing state requirements except that:

 


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