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COMPLIANCE,
PERMITS,
& ENFORCEMENT
COMPLIANCE,
PERMITS,
& ENFORCEMENT

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Evolving Standards for Due Diligence and Vapor Intrusion: Consider State Guidance and Policy
As regulation of vapor intrusion continues to evolve and escalate costs at contaminated sites, due diligence practices for vapor...
Jul 17, 20235 min read


Planning for Success: Launching and Implementing an ESG Program
There is a difference between launching an ESG program and launching a successful ESG program, according to three experts on a June 1,...
Jun 6, 20232 min read


SB 54: Who Must Comply with California's Plastics and Packaging Act? The Gummy Bear Question
California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act (the “Act” or “SB 54”)[1] is a variation of the...
May 3, 20236 min read


When Must Businesses Join a PRO under California's Plastic & Packaging Law? (Updated 11/17/23)
By Catherine W. Johnson On March 29, 2023, the California Department of Resources Recycling and Recovery (CalRecycle) held a workshop[1]...
Mar 31, 20233 min read


CalRecycle Begins to Implement California's Plastic and Packaging Act
On February 28, 2023, the California Department of Resources Recycling and Recovery, known as CalRecycle, held an informational workshop...
Mar 26, 20232 min read


California Draft Vapor Intrusion Guidance Now Final
On February 23, 2023, California EPA (Cal EPA) finally released a “final draft” version of the much-awaited vapor intrusion guidance,...
Feb 24, 20232 min read


Materials Covered under California's Plastics Legislation
California’s SB 54, or the Plastic Producer Responsibility Act, represents a substantial expansion of the increasingly popular form of...
Feb 19, 20231 min read


New Decision Limits Scope of Prop 65
In a landmark decision, a California appellate court ruled that only "direct" exposures are subject to Proposition ("Prop") 65 warning...
Sep 27, 20221 min read


It's a Global World: Product Stewardship
For a variety of reasons (e.g., consumer/shareholder demands, laws regulating chemical use, potential liabilities, corporate...
Jun 7, 20223 min read


ESG Checklist -- A Prop 65 Compliance Program?
In California, the Proposition (“Prop”) 65[1] landscape continues to evolve – notices of violations (“NOVs”) issued for products that do...
Feb 1, 20225 min read


California's Prop 65 - Companies with Fewer than 10 Employees (Updated, March 6, 2023)
By Catherine W. Johnson Companies with fewer than ten employees are exempt from California’s Proposition 65 warning requirements but may...
Feb 8, 20213 min read


Getting Tough on Vapor Intrusion: Enforcement for Failure to Mitigate
by Catherine W. Johnson As concerns have escalated about vapor intrusion, regulatory agencies are not only taking more conservative...
Nov 24, 20202 min read


New Vapor Intrusion Requirements in California Increasing Costs and Liabilities
By Catherine W. Johnson In February 2020, California EPA (Cal-EPA) released its Draft Supplemental Vapor Intrusion Guidance (“Draft...
Jul 22, 20203 min read


Proposition 65 Warnings for Contaminated Properties and Vapor Intrusion
By Catherine W. Johnson, Partner, Environmental General Counsel LLP July 8, 2020 -- While the vast majority of Proposition 65 claims...
Jul 8, 20205 min read


Public Comments on California’s New Vapor Draft Intrusion Guidance: What Next?
By Catherine W. Johnson Public comments on California’s Draft Supplemental Vapor Intrusion Guidance (“DSVIG”) were due to Cal-EPA by June...
Jun 10, 20203 min read


The Latest On Vapor Intrusion Regs In California
By Catherine Johnson Law360 (March 21, 2019, 4:06 PM EDT) Vapor intrusion — the presence of contaminated vapors inside buildings — can...
Mar 21, 20196 min read
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