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Articles by Ryan Trail
Don’t Be Fooled by the Rollbacks: EPA’s PFAS Enforcement Agenda Is Moving Forward
As the Trump Administration works to roll back environmental regulations across the board, many EHS professionals have understandably been watching for signs PFAS regulation might follow the same trajectory. The picture which has emerged, however, is more complicated, and in some respects more restrictive. On two of the most consequential PFAS regulatory fronts, EPA is not retreating. On the contrary, the Agency is pressing forward.
Don’t Be Fooled by the Rollbacks: EPA’s PFAS Enforcement Agenda Is Moving Forward
As the Trump Administration works to roll back environmental regulations across the board, many EHS professionals have understandably been watching for signs PFAS regulation might follow the same trajectory. The picture which has emerged, however, is more complicated, and in some respects more restrictive. On two of the most consequential PFAS regulatory fronts, EPA is not retreating. On the contrary, the Agency is pressing forward.
EPA Proposes Broad PFAS Reporting Exemptions Under TSCA, While Shortening Reporting Window | JD Supra
EPA recently issued a proposed rulemaking, here, which would significantly modify 2023 PFAS reporting regulations under TSCA Section 8(a)(7), introducing several industry-requested exemptions and narrowing who must report. The proposed rule is a major shift from the Biden-era rule, which industry widely criticized as overly burdensome and costly.
EPA Proposes Broad PFAS Reporting Exemptions Under TSCA, While Shortening Reporting Window
EPA recently issued a proposed rulemaking, here, which would significantly modify 2023 PFAS reporting regulations under TSCA Section 8(a)(7), introducing several industry-requested exemptions and narrowing who must report. The proposed rule is a major shift from the Biden-era rule, which industry widely criticized as overly burdensome and costly.
Environmental Notes - January 2026
By Henry R. “Speaker” Pollard, V As the United States seeks to maintain primacy in data processing and artificial intelligence, the Trump Administration is taking steps to reduce the regulatory burdens for development of data centers necessary to sustain this dominance. Perhaps chief among these is President Trump’s Executive Order 14318 issued on July 23, 2025, and titled “Accelerating Federal Permitting of Data Center Infrastructure” (E.O. 14318).
EPA Considers New TSCA Rules for Common Solvent PCE | JD Supra
On July 30, 2025, the U.S. Environmental Protection Agency (EPA) issued a request for public comment on the potential regulation of perchloroethylene (PCE) under the Toxic Substances Control Act (TSCA). PCE is a widely used chlorinated solvent found in numerous industrial applications, including vapor degreasing, precision cleaning, adhesives, coatings, and intermediate chemical manufacturing.
EPA Considers New TSCA Rules for Common Solvent PCE
On July 30, 2025, the U.S. Environmental Protection Agency (EPA) issued a request for public comment on the potential regulation of perchloroethylene (PCE) under the Toxic Substances Control Act (TSCA). PCE is a widely used chlorinated solvent found in numerous industrial applications, including vapor degreasing, precision cleaning, adhesives, coatings, and intermediate chemical manufacturing.
TSCA Test Marketing Exemption for New Chemicals: A Recent Case Study | JD Supra
On July 24, 2025, U.S. Environmental Protection Agency (EPA) approved a Test Marketing Exemption (TME) under section 5(h)(1) of the Toxic Substances Control Act (TSCA) for a confidential new chemical substance (TME Application No. T-24-0001).
Environmental Notes - July 2025 | JD Supra
By Ethan R. Ware EPA’s controversial “Once in, always in, Rule” (Once in Rule) was recently rescinded under the Congressional Review Act, a statute which gives Congress the authority to overturn agency rules if such action is taken within specified time frames after the rules is adopted. A joint resolution Congressional resolution disapproving the rule, adopted by both the Senate and the House, was signed into law by President Trump on June 20, 2025.
TSCA Test Marketing Exemption for New Chemicals: A Recent Case Study
On July 24, 2025, U.S. Environmental Protection Agency (EPA) approved a Test Marketing Exemption (TME) under section 5(h)(1) of the Toxic Substances Control Act (TSCA) for a confidential new chemical substance (TME Application No. T-24-0001).
Drumming Up a Change? EPA’s Review of the RCRA “Empties” Rule and Its Impact on Generators and the Drum Reconditioning Industry | JD Supra
EPA recently initiated a rulemaking process aimed at reviewing how empty industrial drums are regulated under the Resource Conservation and Recovery Act (RCRA). This is a move which could have significant implications for businesses generating, managing, or reconditioning used containers.
Carolinas Environmental Legislative Update | JD Supra
Both the North and South Carolina legislatures have recently adopted statutes affecting environmental issues in their respective states. This update highlights the most significant developments in North and South Carolina. North Carolina The return of a Republican supermajority to the North Carolina General Assembly saw the return of significant environmental policy changes through legislation.
Environmental Notes - July 2025
EPA’s controversial “Once in, always in, Rule” (Once in Rule) was recently rescinded under the Congressional Review Act, a statute which gives Congress the authority to overturn agency rules if such action is taken within specified time frames after the rules is adopted. A joint resolution Congressional resolution disapproving the rule, adopted by both the Senate and the House, was signed into law by President Trump on June 20, 2025.
PFAS and Your Wastewater Discharge Permit: What to Know and How PFAS Affects Permit Requirements | JD Supra
Beginning with the PFAS Action Plan of 2019, it became clear to industry observers and environmental professionals that EPA intends to regulate PFAS compounds in industrial wastewater permits.
Environmental Notes - July 2023 | JD Supra
North Carolina Proposes New Guidance for Vapor Intrusion Assessment and Mitigation - The North Carolina Department of Environmental Quality (DEQ) has drafted new and revised guidance documents for the assessment and mitigation of vapor intrusion (VI) at properties undergoing reuse and redevelopment (Draft Guidance).
Environmental Notes - July 2023
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PFAS and Your Wastewater Discharge Permit: What to Know and How PFAS Affects Permit Requirements |..
Beginning with the PFAS Action Plan of 2019, it became clear to industry observers and environmental professionals that EPA intends to regulate PFAS compounds in industrial wastewater permits.
CERCLA Release Reporting Exemption for Federally Permitted Releases | JD Supra
Seasoned environmental professionals are well-acquainted with the typical hazardous substance release reporting analysis under CERCLA; where a reportable quantity of a hazardous substance is released into the environment within a 24 hour period, CERCLA section 103 requires a person in charge, upon gaining knowledge of the release, to report it immediately to the National Response Center. CERCLA enforcement actions for failure to timely report releases are common and costly.
Environmental Notes - December 2022 | JD Supra
EPA Proposes to Expand TRI Reporting Requirements for PFAS and Other Chemicals of Special Concern - EPA is proposing to add per- and polyfluoroalkyl substances (“PFAS”) subject to reporting under the Emergency Planning and Community Right-to-Know Act (“EPCRA”) and the Pollution Prevention Act (“PPA”) pursuant to the National Defense Authorization Act for Fiscal Year 2020 (“NDAA”) to the list of Lower Thresholds for Chemicals of Special Concern ("chemicals of special concern").
Environmental Notes - December 2022
Submitted by tharris on December 15, 2022 - 3:03pm News Environmental Notes - December 2022 Click on the image below for a full PDF of the Environmental Newsletter.
The It Couple: Environmental Justice And PFAS
United States: The It Couple: Environmental Justice And PFAS 29 March 2022 Williams Mullen EPA recently held its first of two public meetings to garner input on environmental justice considerations related to the development of the proposed per- and polyfluoroalkyl substances (PFAS) national primary drinking water regulation (NPDWR) under the Safe Drinking Water Act.
Environmental Notes - March 2022 | JD Supra
On January 24, 2022, the United States Supreme Court granted an appeal to reconsider the extent of federal Clean Water Act (CWA) jurisdiction involving wetlands on a couple’s property in Idaho. The appellants (the Sacketts) are no strangers to the Supreme Court: in 2012, they won a landmark procedural case when the Court held that they could appeal an EPA unilateral administrative order before EPA actually tried to enforce it (“Sacket I”).
Environmental Notes - March 2022
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The It Couple: Environmental Justice and PFAS
03.25.2022 The It Couple: Environmental Justice and PFAS By: Ryan W. Trail EPA recently held its first of two public meetings to garner input on environmental justice considerations related to the development of the proposed per- and polyfluoroalkyl substances (PFAS) national primary drinking water regulation (NPDWR) under the Safe Drinking Water Act.
Williams Mullen Manufacturing Edge: Environmental Enforcement in the Current Regulatory Climate | JD Supra
THE MATTERS DESCRIBED IN THIS VIDEO ARE ILLUSTRATIVE OF THE MATTERS HANDLED BY THE FIRM. MATTER RESULTS DEPEND UPON A VARIETY OF FACTORS UNIQUE TO EACH MATTER. NOT ALL MATTER RESULTS ARE PROVIDED. MATTER RESULTS DO NOT GUARANTEE OR PREDICT A SIMILAR RESULT IN ANY FUTURE MATTER UNDERTAKEN BY THE FIRM.
Williams Mullen Manufacturing Edge: Environmental Enforcement in the Current Regulatory Climate
12.07.2021 Williams Mullen Manufacturing Edge: Environmental Enforcement in the Current Regulatory Climate By: Liz Williamson & Ryan W. Trail THE MATTERS DESCRIBED IN THIS VIDEO ARE ILLUSTRATIVE OF THE MATTERS HANDLED BY THE FIRM. MATTER RESULTS DEPEND UPON A VARIETY OF FACTORS UNIQUE TO EACH MATTER. NOT ALL MATTER RESULTS ARE PROVIDED. MATTER RESULTS DO NOT GUARANTEE OR PREDICT A SIMILAR RESULT IN ANY FUTURE MATTER UNDERTAKEN BY THE FIRM.
Unpacking the TSCA Polymer Exemption | JD Supra
Manufacturers of chemical substances in the United States are well aware of the regulatory burdens placed on their industry by the Toxic Substances Control Act (TSCA). TSCA requirements can be cumbersome and difficult to understand. Fortunately, TSCA contains several exemptions offering relief for companies in certain circumstances.
Unpacking the TSCA Polymer Exemption
10.07.2021 Unpacking the TSCA Polymer Exemption By: Ryan W. Trail Manufacturers of chemical substances in the United States are well aware of the regulatory burdens placed on their industry by the Toxic Substances Control Act (TSCA). TSCA requirements can be cumbersome and difficult to understand. Fortunately, TSCA contains several exemptions offering relief for companies in certain circumstances.
Environmental Notes - October 2021 | JD Supra
Like everything else today, the definition of “Waters of the United States” (WOTUS) under the Clean Water Act (CWA) ebbs and flows depending on which political party holds office.
Environmental Notes - October 2021
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Ryan Trail and Ethan Ware Named Among South Carolina's "Legal Elite"
08.06.2021 Ryan Trail and Ethan Ware Named Among South Carolina's "Legal Elite" Williams Mullen is pleased to announce that environmental attorneys Ryan Trail and Ethan Ware have been named among South Carolina's "Legal Elite" by Columbia Business Monthly (CBM) and Greenville Business Magazine (GBM), respectively.
Regulation of PFAS in Wastewater Permits: Recent Guidance and Rulemaking Actions by EPA | JD Supra
A recent rulemaking from EPA seeks the assistance of industry and the public in developing new effluent limitation guidelines to regulate per- and polyfluoroalkyl substances (“PFAS”) in wastewater discharges from facilities manufacturing or formulating these compounds. PFAS are a group of chemical compounds found in a wide array of consumer and industrial products and are widespread and persistent in the environment.
Environmental Notes - May 2021
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Regulation of PFAS in Wastewater Permits: Recent Guidance and Rulemaking Actions by EPA | Williams.
05.04.2021 Regulation of PFAS in Wastewater Permits: Recent Guidance and Rulemaking Actions by EPA By: Ryan W. Trail A recent rulemaking from EPA seeks the assistance of industry and the public in developing new effluent limitation guidelines to regulate per- and polyfluoroalkyl substances (“PFAS”) in wastewater discharges from facilities manufacturing or formulating these compounds.
Closure Requirements for Large Quantity Generators under the Hazardous Waste Generator Improvements Rule | JD Supra
Large quantity generators (LQGs) of hazardous waste who accumulate hazardous waste for no more than 90 days know proper adherence to unit-specific and facility-wide closure requirements is an essential condition for exemption from permitting. For facilities in states where the Hazardous Waste Generator Improvements Rule (HWGIR) has been adopted, closure requirements have changed. These states include South Carolina, North Carolina, Virginia, and 28 others.
Closure Requirements for Large Quantity Generators under the Hazardous Waste Generator Improvements.
03.03.2021 Closure Requirements for Large Quantity Generators under the Hazardous Waste Generator Improvements Rule By: Ryan W. Trail Large quantity generators (LQGs) of hazardous waste who accumulate hazardous waste for no more than 90 days know proper adherence to unit-specific and facility-wide closure requirements is an essential condition for exemption from permitting.
Emergency Preparedness and Prevention under the Hazardous Waste Generator Improvements Rule | JD Supra
Generators of hazardous waste have long understood the importance of emergency preparedness and prevention to regulatory compliance and facility safety. Contingency planning and coordination with emergency service providers have been requirements of RCRA regulations for many years. For states that have adopted the Hazardous Waste Generator Improvements Rule (HWGIR), however, new and more stringent requirements for emergency preparedness and prevention now apply.
Environmental Notes - January 2021
Click on the image below for a full PDF of the Environmental Newsletter.
Emergency Preparedness and Prevention under the Hazardous Waste Generator Improvements Rule
01.05.2021 Emergency Preparedness and Prevention under the Hazardous Waste Generator Improvements Rule By: Ryan W. Trail Generators of hazardous waste have long understood the importance of emergency preparedness and prevention to regulatory compliance and facility safety. Contingency planning and coordination with emergency service providers have been requirements of RCRA regulations for many years.
Beat the Clock: Timely Reporting of Releases of Hazardous Substances | JD Supra
The obligation of manufacturing facilities to report releases of hazardous substances to local, state, or federal authorities is a complex regulatory subject. Multiple variables may impact whether a facility with a release to the environment can expect an enforcement action if the release isn’t reported as required by law.
Environmental Notes - July 2020 | JD Supra
Two recent executive orders (“EOs”) issued by President Trump require additional efforts by federal agencies to facilitate regulatory reform and to expedite infrastructure projects, relying greatly on emergency and special exception authorities within federal statutes and regulations. One EO, issued May 19 and entitled, “Executive Order on Regulatory Relief to Support Economic Recovery,” focuses on general regulatory relief in the face of the COVID- 19 pandemic (“Regulatory Relief EO”).
EPA Amends TSCA Definition of “Small Manufacturer” | JD Supra
EPA recently issued a final rule amending Toxic Substances Control Act (TSCA) regulations concerning “small manufacturers” of chemical substances. Companies that meet the regulatory definition of a “small manufacturer” of chemical substances are exempt from certain reporting and recordkeeping obligations under TSCA.
EPA Issues Final Rule for Civil Compliance Inspection Procedures | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
EPA Issues Temporary Advisory for NPDES Reporting During COVID-19 | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
EPA Issues COVID-19 Guidance on Enforcement Discretion | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Containment Area Releases and the Limits of CERCLA Release Reporting Obligations | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Environmental Notes - February 2020 | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Environmental Consultants Face Potential Legal Liability | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Environmental Notes - August 2019 | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
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