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Mar 27, 2023

EPA Publishes Draft “Cumulative Risk” Assessment Procedures Under TSCA

The EPA has release a proposed guidance document for conducting cumulative risk assessments (“CRA”) under the Toxic Substances Control Act (“TSCA”). The guidance is designed to assist the EPA to characterize and quantify the combined risk to health and/or the environment from multiple chemical agents and/or stressors. Under the Biden Administration, consideration of cumulative risk is a top priority for the EPA in its efforts to address environmental justice concerns. The draft guidance notes that disadvantage communities often face multiple pollutants from multiple media which overlap with the adverse effects of poverty and other socioeconomic factors. However, it takes a… Read more


Apr 24, 2020

U.S. Supreme Court Issues Decision Regarding How the Federal Clean Water Act Applies to Groundwater Discharges

Groundwater Testing

On April 23, 2020, the U.S. Supreme Court issued a decision in County of Maui v. Hawaii Wildlife Fund, a closely watched case regarding whether the federal Clean Water Act (CWA) applies to discharges of pollutants to groundwater which reach surface waters. In County of Maui, the plaintiff environmental organizations brought a citizen suit alleging that the defendant-county was in violation of the CWA in regard to the county’s decades-old practice of injecting partially treated wastewater into groundwater wells.  The wells consistently leaked and tracer dye testing confirmed that over 60% percent of the wastewater injected into the wells wound… Read more