What a Freeze on New Regs Means for Environmental and Safety Rules in 2025
Several EPA Rules Covered by New Executive Order
Among the Executive Orders signed by President Trump on Day 1 of his second term was an order to “freeze” ongoing regulatory actions and to postpone, where appropriate, the effective dates for recently published rules.The order, Regulatory Freeze Pending Review, directs Federal agencies like US DOT, EPA, OSHA, and others to:
- Withdraw unpublished rules to be reviewed and approved by a department or agency head appointed by the President since taking office.
- Consider postponing for 60 days (or more, as appropriate) the effective date for any rules that were published but have not yet taken effect.
- Consider re-opening the comment period on postponed rules.
Environmental Actions Withdrawn Or Delayed
With a Final Rule, EPA has delayed the effective date for four recent rulemakings.The following Final Rules now have an effective date of March 21, 2025:
- Trichloroethylene (TCE), Final Rule Under TSCA (Details)
- Revisions to Guidelines on Air Quality Models (Details)
- State Air Plan Approval for Illinois (Details)
- State Air Plan Revisions for California (Details)
In addition, a forthcoming proposed rule to create new water pollution limits for manufacturers of PFAS was reportedly withdrawn from consideration by the Office of Management and Budget (OMB) on January 21.
A new Executive Order puts a temporary "freeze" on new and pending regulations.
EPA Final Rules with Upcoming Effective Dates
In the rule delaying the four rules above, EPA states that the agency "may identify additional regulations in subsequent notices." Other recently published EPA Final Rules with upcoming effective dates that could be delayed a minimum of 60 days include:- A revised, more stringent secondary NAAQS for sulfur dioxide (SO2), and updates to the related data handling provisions. (Original effective date: January 27, 2025).
- New Significant New Use Rules (SNURs) for about 30 chemical substances subject to pre-manufacture notifications (PMNs) under TSCA. (February 10, 2025)
- A rule adding five amendments to the RCRA hazardous waste regulations. These five updates were withdrawn previously, after EPA received adverse public comments. (February 10, 2025).
Lion Members: The Monthly Regulatory Summary available to you is especially valuable at times like this! View the latest summary here to see all significant final rules, proposed rules, agency notices, public outreach, and other rulemaking activity published in December 2024.
Check out this Member Bulletin for insights about how a "regulatory freeze" will impact ongoing EH&S concerns like OSHA's heat exposure rule, regulation of PFAS, chemical risk evaluations under TSCA, and more.
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