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Sean Grady, CHMM – Environmental Transformation Podcast

Sponsored Content

Environmental Protection Agency Issues its Spring 2025 Regulatory Agenda – Read more here

Department of Transportation Issues Spring 2025 Regulatory  Agenda – Read more here

Department of Labor Issues its Spring 2025 Regulatory Agenda – Read more here

IHMM Stands with the Workplace EHS Coalition to Champion Worker Safety in the FY2026 Federal Budget

Environmental News for This Week

1. Significant Staff Furloughs at United States Environmental Protection Agency (EPA):
The EPA announced that if the continuing federal funding lapse extends into November, it may need to furlough up to 89 % of its workforce—over 10,000 employees—despite interim carry-over funding. From a legal-risk perspective, this poses heightened concerns: reduced staffing may delay enforcement actions, slow rule-making schedules, impair permitting reviews, and increase uncertainty for regulated entities in sectors subject to statutory deadlines and agency oversight.

2. Potential Weakening of the National Environmental Policy Act (NEPA) Framework and Scientific Infrastructure:
Recent commentary indicates that foundational NEPA protections are under threat, and the EPA is reportedly dismantling or reallocating resources from its key risk-analysis database (IRIS) and core scientific review capacities.  The implications are substantial: agencies and permit applicants may face reduced predictive modelling of environmental impacts; challenges to agency actions may increase on procedural grounds; and liability risk may shift as the scientific underpinning for environmental reviews erodes.

3. EPA TSCA Operations Amid Federal Shutdown

Despite the ongoing federal government shutdown, the U.S. Environmental Protection Agency’s implementation of the Toxic Substances Control Act (TSCA) has continued—albeit at a diminished capacity. The agency has been operating under its contingency plan, activated on October 1 after Congress failed to pass appropriations for Fiscal Year 2026.

Under that plan, EPA exhausted any remaining reserve funds and subsequently furloughed approximately 89 percent of its workforce. While certain essential functions—such as the protection of human health and environmental safety—have been maintained, most day-to-day activities, including TSCA new-chemical reviews, risk evaluations, and regulatory actions, have slowed significantly.

Industry stakeholders are increasingly concerned that a prolonged disruption will compound existing backlogs in chemical review and rulemaking, delay critical risk determinations, and unsettle compliance timelines for manufacturers and importers. Even a temporary lapse in normal operations can ripple through the broader regulatory ecosystem, creating uncertainty in product approvals, testing obligations, and enforcement expectations that could take months to resolve once full funding is restored.

Conclusion:
These developments signal a potential shift in the balance of regulatory oversight and agency capacity. Private-sector actors should assess exposure to delays in permitting, enforcement unpredictability, and evolving standards of care in environmental compliance. Agencies and counsel should monitor how reduced staffing and scientific capacity affect the legal defensibility of permits, review decisions, and enforcement actions.

Workplace Safety News This Week

1. The Occupational Safety and Health Administration (OSHA) disclosed that its operations have been significantly curtailed under the current federal funding lapse—routine inspections, site visits, training programmes and enforcement activities have been largely suspended. From a liability standpoint, employers should be mindful that reduced federal oversight may shift greater risk onto internal compliance regimes, and insurance carriers may reassess exposures tied to diminished external enforcement.
2. Coverage indicates that OSHA’s publicly accessible News Release portal is no longer being updated due to the funding impasse. This lack of transparency raises issues of notice to regulated entities, potential defense arguments in enforcement actions, and the possibility of increased litigation risk if accidents occur in the absence of active federal monitoring.

In sum, the shutdown’s impact on workplace-safety governance suggests elevated legal exposure for employers: internal audit thresholds must be raised, independent risk assessments should be accelerated, and contractual indemnities revisited—particularly in sectors reliant on federal inspections (construction, transportation, manufacturing). Stakeholders should treat this as a transitional risk-window until federal normalcy resumes.

Federal Shutdown Continues

As of November 3, 2025, the federal government remains in shutdown, now extending into its 33rd day. This week marks the longest federal shutdown in the nation’s history. Congress has remained deadlocked: the Donald Trump Administration and the House GOP insist no negotiations will proceed until the government reopens, while Senate Democrats refuse to support a clean continuing resolution absent agreement on health-care subsidies and social-services funding.

Key federal operations continue under mandatory appropriation or essential-services exemptions, but most discretionary programs remain suspended or severely impaired. Federal employees endure missed pay — both furloughed and “excepted” workers — and approximately 42 million Americans face disruption of food-assistance benefits under the Supplemental Nutrition Assistance Program (SNAP).

Legally, the impasse is governed by the Anti-Deficiency Act, which imposes rigid restrictions on agency spending during a lapse in appropriations, and the Fair Treatment Act, which intends retroactive compensation for furloughed employees once funding resumes.

Economically, the Congressional Budget Office estimates the shutdown may reduce fourth-quarter GDP by up to 2 percent and impose permanent losses of $7 billion–$14 billion, depending on duration.

Absent a bipartisan agreement or legislative breakthrough, the stalemate is likely to persist, with escalating legal, economic, and social consequences.

DG Transportation Issues

IHMM Global DG Transport Compliance Matrix (2025–2026)

United States

While no major final rule specifically under the DG/UN/ADR regime was publicly announced this week in the U.S., the industry buzz around the upcoming International Air Transport Association (IATA) 2026 manual issuance (which will impact air-dangerous goods shipping) signals U.S. shippers should prepare for alignment. An article notes that IATA has just unveiled the 2026 editions of its cargo/ground operations manuals, which include nearly 100 updates — including battery and lithium-ion battery shipping controls.

Implication: Although purely U.S. road/rail DG regulation under ADR (U.S. is not a direct contracting party) remains unchanged this week, U.S. exporters and multimodal carriers should monitor and plan for the shifts in air/sea DG transport standards, as these will affect supply-chain contracts, documentation, and international export compliance.

Europe

In Europe, the regulatory baseline for road-transport DG—ADR 2025—remains effective (entered 1 January 2025) and there were no fresh ADR amendment publications announced this week. Nonetheless, the broader context remains one of rapid change: training, documentation, packaging, battery/vehicle entries are still in transition. For example, some European guidance sources continue to emphasise that ADR 2025 adds new UN entries (UN 3551-3560) and waste-transport changes.

Implication: Legal practitioners in Europe should remind clients that although no “new” amendment was announced this week, the operational regime is still newly in force and enforcement risk is increasing as transition periods expire. Carriers, drivers, consignors must demonstrate compliance with ADR 2025 even though the “newness” may lull them into assuming grace periods still exist.

Asia

In Asia, this week’s headlines did not reveal a region-wide ADR accession or major UN Model Regulations adoption directly under UNECE auspices. Nonetheless, the IATA 2026 manual release (as referenced above) has global impact—including Asian air/sea shippers.

Implication: For DG transport in Asia involving international legs, practitioners should treat the IATA update as a signal to align national/regional systems with upcoming global battery/vehicle/liquid-cargo changes, even if domestic road/rail DG laws remain unchanged. Contracts should anticipate this shift.

Africa

No major announcement this week under the UNECE ADR accession roadmap for Africa was published. The continent continues to be in a transitional phase regarding adoption of ADR or full alignment with UN Model Regulations.

Implication: Legal advisors should counsel their African-based clients to maintain heightened vigilance—while there may not be fresh ADR accessions this week, the global “update wave” (batteries, packaging, training) means that national regimes may announce implementing regulations without much notice. Proactive gap-analysis remains prudent.

Central & South America

A notable development: In Mexico, following a recent tanker explosion in Mexico City (September 2025), the federal government announced two new regulations for the transportation and distribution of liquified petroleum gas (LPG).
Key elements of the new Mexican rules:

• Companies transporting/distributing LPG must annually demonstrate to the regulator (Agencia de Seguridad, Energía y Ambiente (ASEA)) that their vehicles are maintained (including container/vessel hydrostatic pressure testing).

• Driver training must be certified to a technical competency standard (not just generic driving training).

• Vehicles must be equipped with GPS and speed-limiters for LPG distribution.

Implication: This week’s Latin-America-specific development shows that national DG/regulations may be triggered by incident-driven risk, not just harmonisation cycles. Practitioners should review LPG/flammable-gas transport protocols in Mexico and neighbouring jurisdictions, ensure contractual parties (consignors, carriers) certify vehicle inspection/maintenance and driver-competency records. Although the rules are specific to LPG, they signal a tightening regulatory environment for bulk-carriage of hazardous liquids in the region.

Resource Highlight: Returning to School After a Crisis

There is no one-size-fits-all approach to supporting students after a traumatic event. The information below contains lessons learned from research on previous school shootings. However, it’s most important to let students know you are there for them, however they need, and encourage them to talk. Learn more here.

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Celebrating Safe Schools Week

This new Spotlight, released today, features NCSS leaders in conversation around evolving school safety needs. They explore emerging concerns like cyber safety and student mental health, and share insights on building trust, strong relationships, and evidence-based approaches for safer, more supportive schools. Watch Now

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STOP School Violence Program FY2025 Funding Opportunity

The Bureau of Justice Assistance (BJA) has announced its STOP School Violence Program FY2025 Funding Opportunity to support initiatives that prevent and reduce school violence through training, threat assessment teams, and other safety strategies. A recording of the informational webinar on this grant is available on our website

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• FY25 Office of Justice Programs Community Based Violence Intervention and Prevention Initiative
• OJJDP FY25 Strategies To Support Children Exposed to Violence

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Additional School Safety Resources

• 11/19 – Enhancing School Safety Using Behavioral Threat Assessment
  Hosted by the Department of Homeland Security

Recent News from the European Chemicals Agency

• Our committees meet in November-December 

• New proposal to harmonise classification and labelling 

• Recordings available: Drinking Water Directive stakeholders workshop 

• Extended deadline: call for evidence on substances in packaging and packaging waste 

• Join us tomorrow: Consultation on PFAS draft opinion – Guidance for respondents 

• Reminder: Applying the (Q)SAR Assessment Framework at ECHA 

• ECHA and EASA strengthen cooperation 

• Hands-on training at JRC Nanobiotechnology Laboratory 

• Updated collection of Board of Appeal's findings and decisions 

• Biocides decisions on Union authorisations