February 24, 2020 Presented by Eric J. Conn, Kate M. McMahon and Beeta B. Lashkari The U.S. Chemical Safety and Hazard Investigation Board (the CSB) has, for the first time, established a chemical release reporting rule that creates broad new requirements for employers to report accidental releases to the CSB within 8 hours if certain thresholds are met. The CSB promulgated this new Accidental Release Reporting Rule because of a 2018 federal district court decision mandating that the CSB issue the rule pursuant to the 1990 Clean Air Act Amendments. The court had set an expedited schedule, giving the CSB only 12 months to develop and finalize the rule. Conn Maciel Carey’s national OSHA • Workplace Safety Practice Group coordinated an ad hoc Coalition of employers and trade associations to prepare rulemaking comments about the proposed rule. While CSB revised the final rule in a few important ways to address the concerns our Coalition raised in our comments, the final rule still includes several problematic requirements that will create major compliance headaches for employers across the country. The rule will take effect in March, 30 days after publication in the Federal Register. Participants in this webinar learned: • History of the CSB’s efforts to promulgate a reporting rule • What was in the Proposed Rule • Comments about the proposed rule submitted by Conn Maciel Carey and our Coalition • Details of the Final Rule, including coverage, contents of the reports, reporting deadlines, etc. • What employers must do now to comply • Potential legal challenges to the rule