COVID-19 Enforcement Relief and Response Policies

Below, our Environmental practice group has collected the latest enforcement actions from various federal and state agencies tasked with regulating environmental policy. We will update this webpage periodically as new guidance and rulemakings are handed down. We encourage you to bookmark this URL and check back for new updates.

Please click on the state you are interested in to view state-specific information:

FEDERAL

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U.S. Environmental Protection Agency

• COVID-19 Implications for EPA's Enforcement and Compliance Assurance Program
• Temporary Advisory for NPDES Reporting in Response to COVID-19 Pandemic
• Interim Guidance on Site Field Work Decisions Due to Impacts of COVID-19
• Frequent Questions About the Temporary COVID-19 Enforcement Policy
• Continuous Emission Monitoring: Quality-Assurance Requirements During the COVID-19 National Emergency
• COVID-19 Implications for EPA's Enforcement and Compliance Assurance Program: Addendum on Termination
• Frequent Questions About the Temporary COVID-19 Enforcement Policy

U.S. Department of Transportation

Pipeline and Hazardous Materials Safety Administration

• Hazardous Materials Notice of Enforcement Policy Regarding Training Requirements
• Pipeline Operators Stay of Enforcement
• Notice of Enforcement Discretion to Gas Pipeline Operators Affected by the Coronavirus Outbreak
• Notice of Enforcement Discretion Regarding Transportation of Certain Sanitizing and Disinfecting Materials During the Coronavirus Disease 2019 Public Health Emergency
• Notice of Enforcement Discretion Regarding Continued Manufacturing of Performance Oriented Packaging (POP) Designs That Have Exceeded Their Periodic Retesting Date
• PHMSA Issues Notice of Enforcement Discretion for Cylinders

Federal Motor Carrier Safety Administration

• Motor Carrier Safety Administration COVID-19 Information & Resources
• Disruptions to Drug and Alcohol Testing Due to the Coronavirus Disease 2019
• Waiver in Response to the COVID-19 Emergency – For States, CDL Holders, CLP Holders, and Interstate Drivers Operating Commercial Vehicles
• Waiver for States Concerning Third Party Skills Test Examiners in Response to the COVID-19 Emergency
• Notice of Enforcement Discretion Concerning Certain Requirements for 10-Day State Notification and other Actions on Driver License Records
• Expanded Frequently Asked Questions for State Driver Licensing Agencies and Commercial Drivers Regarding Permissible Actions During the COVID-19 Emergency

Federal Railroad Administration

• FRA Response to Request for Relief Regarding Training Requirements
• FRA Response to Request for Relief Regarding Certain Safety Requirements
• FRA Response to Request for Relief Regarding Drug and Alcohol Testing
• FRA Guidance on Drug & Alcohol Testing Requirements During the COVID-19 Public Health Emergency
• FRA Individual Relief Request Responses

Federal Aviation Administration

• FAA Grants Exemption for Certain Air Ambulance Personnel
• FAA Grants Exemption Pertaining to Flight Attendant Regulations

Federal Highway Administration

• Notice of Enforcement Discretion–Operation of Commercial Food Trucks in Federally Funded Interstate Highway Rest Areas

Occupational Safety & Health Administration

• Temporary Enforcement Guidance- Healthcare Respiratory Protection Annual Fit-Testing for N95 Filtering Facepieces During the COVID-19 Outbreak
• Enforcement Guidance for Respiratory Protection and the N95 Shortage Due to the Coronavirus Disease 2019 Pandemic
• Enforcement Guidance for Use of Respiratory Protection Equipment Certified under Standards of Other Countries or Jurisdictions During the Coronavirus Disease 2019 (COVID-19) Pandemic
• Expanded Temporary Enforcement Guidance on Respiratory Protection Fit-Testing for N95 Filtering Facepieces in All Industries During the Coronovirus Disease 2019 (COVID-19)
• Discretion in Enforcement when Considering an Employer’s Good Faith Efforts During the Coronavirus Disease 2019 Pandemic
• Enforcement Guidance on Decontamination of Filtering Facepiece Respirators in Healthcare During the Coronavirus Disease 2019 Pandemic
• Updated Interim Enforcement Response Plan for Coronavirus Disease 2019 (COVID-19)
• Revised Enforcement Guidance for Recording Cases of Coronavirus Disease 2019 (COVID-19)

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STATE-BY-STATE

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Alabama

Environment

• COVID-19 Temporary Advisory for Discharge Monitoring Reports

Motor Carrier Transportation

• Weight Limit Increased for COVID-19 Relief Efforts
• Suspension of IRP and IFTA for Interstate Relief Efforts
• Extension of Time for Motor Vehicle Registration and Paying Property Taxes on Vehicles

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Alaska

Environment

• COVID-19 Caused Non-Compliance Concerns, No Action Assurance Memorandum (air quality)
• COVID-19 Caused Non-Compliance Concerns, No Action Assurance Memorandum (water quality)
• COVID-19 Caused Non-Compliance Concerns, No Action Assurance Memorandum (underground storage tanks)
• Landfill Groundwater and Surface Water Monitoring During COVID-19
• Operator Certification Compliance Guidance During COVID-19 Pandemic
• COVID-19 Caused Non-Compliance Concerns, No Action Assurance Memorandum (Spill Prevention and Response)

Motor Carrier Transportation

• Commercial Driver's Licenses Extended

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Arizona

Environment

• Memorandum of Compliance and Enforcement Implementation during COVID-19
• Continuing ADEQ Operations While Slowing the Spread

Motor Carrier Transportation

• Weight Limits Eased for Delivery of Essential Supplies
• License Expirations Extended

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Arkansas

Environment

• Provisional COVID-19 Enforcement Guidance
• ADEQ COVID-19 Resources & Information
• Arkansas Department of Energy and Environment Enforcement Guidance
• ADEQ Emergency Order Regarding License Renewals

Motor Carrier Transportation

• Arkansas DOT Emergency Relief Provisions on FMCSR and Weight Limits

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California

Environment

• “CARB’s regulations continue to be in effect and deadlines apply.” Message from CARB in response to COVID-19
• Compliance with Water Board Requirements During the Coronavirus 2019 (COVID-19) Emergency
• South Coast AQMD COVID-19 Updates
• Implementation of Underground Storage Tank Requirements During Government Imposed Coronavirus 2019 (COVID-19) Public Health and Safety Restrictions
• CalEPA Issues Statement on Compliance with Regulatory Requirements During the COVID-19 Emergency
• CalRecycle Guidance: Emergency Waiver of Standards which may be used by solid waste facilities with COVID-19 impacts
• CalRecycle Guidance for Recycling Centers
• Advisory on the Management of Hazardous Waste by Generators, Transporters, Electronic Waste Handlers, and Tiered Permit Facilities During the Coronavirus Disease 2019 Pandemic
• Advisory on the Management of Hazardous Waste by Permitted Treatment, Storage and Disposal Facilities During the Coronavirus Disease 2019 Pandemic

Motor Carrier Transportation

• License Extensions

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Colorado

Environment

• Extension of Asbestos and Lead certifications
• Frequently Asked Questions for the Air Pollution Control Division
• Water and COVID-19-Frequently Asked Questions  (See Questions 36 and 37 regarding discharge monitoring reports and inspections)
• Temporary Guidance for Complying with Hazardous Waste Requirements During COVID-19 Response
• Solid Waste Waivers due to COVID-19 Impacts

Motor Carrier Transportation

• Emergency Waiver related to driver’s license extensions COVID-19 Emergency Waiver
• Colorado CDL Impact During Closure and Extension of CDL licenses
• COVID-19 Information for CMV Companies and Drivers

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Connecticut

Environment

• DEEP COVID-19 Response – a few deadlines are extended
• DEEP Enforcement Discretion Statement During the COVID-19 Emergency

Motor Carrier Transportation

• Connecticut DMV IRP Waiver
• COVID 19 Waiver of FMCSRs
• Credentials Extension: 90-day extension for expiring DMV credentials

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Delaware

Environment

• No policy change identified as of 7/20/2020

Motor Carrier Transportation

• CDL Drivers with Expired Medical Certification May Renew
• Waiver of IRP and IFTA Requirements for Delaware

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District of Columbia

Environment

• Implementation of Underground Storage Tank Requirements During Government Imposed Coronavirus 2019 Public Health and Safety Restrictions

Motor Carrier Transportation

• IRP Waivers
• License Deadlines Extended

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Florida

Environment

• Emergency Order Due to the Effects of COVID-19 – Extends certain deadlines for 30 days

Motor Carrier Transportation

• COVID-19 Emergency Order – Extends drivers licenses
• Office of Commercial Vehicle Enforcement Emergency Declarations
• COVID-19 Public Health Emergency Third Amended Emergency Order

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Georgia

Environment

• Link to Response to Questions about COVID-19 Implications for EPD's Compliance and Enforcement

Motor Carrier Transportation

• Governor Orders Relaxing Rules on Hours of Service and other Requirements – See 3/14/2020 for hours of service and 3/25/2020 for certain CDL provisions

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Hawaii

Environment

• Temporary Policy Regarding Compliance Issues Due to the Coronavirus Disease 2019 Pandemic (Clean Air Branch)
• COVID-19 and Hazardous Waste Generators

Motor Carrier Transportation

• COVID-19 CDL FAQs
• COVID-19 Safety Check FAQs
• HDOT COVID-19 Update: Identification Credentials, Safety Checks, and Vehicle Registrations

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Idaho

Environment

• Links to IDEQ COVID-19 Responses
• COVID-19 Regulatory Flexibility and Compliance Assistance

Motor Carrier Transportation

• Driving & Identification Credential Extensions
• Relief for the Motor Carrier Rules, Due to Coronavirus Disease 2019

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Illinois

Environment

• Illinois Environmental Protection Agency Compliance Expectations Statement

Motor Carrier Transportation

• Illinois Waiver for Overweight Vehicles
• Movement of Loads in Response to COVID-19 Pandemic on Roads Under Jurisdiction of State of Illinois

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Indiana

Environment

• IDEM Statement on Enforcement Discretion

Motor Carrier Transportation

• Declaration Extending Drivers Licenses
• Relief from Hours of Service Requirements
• Intrastate Motor Carriers, International Registration Plan, Base Plate Registrations, and International Fuel Tax Agreement Waivers in Response to COVID-19

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Iowa

Environment

• Link to DNR Enforcement Discretion and Compliance Protocol

Motor Carrier Transportation

• Driver's License Extensions
• Iowa DOT COVID-19 Public Response

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Kansas

Environment

• Letter from Director of Environment to Kansas Regulated Community

Motor Carrier Transportation

• Driver's Licenses and Registrations Extended
• Executive Order 20-09-Conditional and temporary relief from certain motor carrier rules and regulations in response to the COVID-19 pandemic
• Motor Carrier Emergency Declarations

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Kentucky

Environment

• Grace Period for Method 9 Certifications
• Memorandum to Waste Management Facilities
• General Discussion of COVID-19
• Regulatory Compliance Impacts from COVID-19
• Application for Temporary COVID-19 Regulatory Flexibility

Motor Carrier Transportation

• Declaration of Emergency, Temporary Suspension of Weight Restrictions, and Exemption of Hours of Service and Stoppage at Weigh Stations
• Declaration of Emergency, 90 Day Extension of Operator's Licenses Expiration Dates and Registration Deadlines

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Louisiana

Environment

• Second Amended Declaration of Emergency and Administrative Order granting relief from certain deadlines
• Third Amended Declaration of Emergency COVID-19
• Fourth Amended Declaration of Emergency and Administrative Order
• Fifth Amended Declaration of Emergency and Administrative Order

Motor Carrier Transportation

• Louisiana DOT OS Waiver | FMCSA
• Waiver Order-DOTD Disaster Relief for Vehicles, Trucks and Loads
• DOD Secretary Wilson extends COVID-19 waiver order for motor carriers to May 31, 2020

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Maine

Environment

• DEP and the Novel Coronavirus 2019 (COVID-19) (Compliance Obligations)
• Wastewater Compliance–Questions and Answers

Motor Carrier Transportation

• CDLs, registrations extended during emergency

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Maryland

Environment

• Order Extending Certain Licenses, Permits, Registrations, and Other Governmental Authorizations, and Authorizing Suspension of Legal Time Requirements
• MDE COVID-19 Update

Motor Carrier Transportation

• Maryland Ex Order Vehicle Weight Limits - 3.18.20 | FMCSA
• Order Vehicle Weight Limits

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Massachusetts

Environment

• MassDEP COVID-19 FAQs for Wastewater Service Providers
• Massachusetts to Temporarily Suspend Bottle Redemption Enforcement
• Hazardous Waste Management Guidance During State of Emergency for COVID-19 Pandemic
• Guidance on Continuity of MassDEP Waste Site Cleanup Operations and MCP Compliance during COVID-19 State of Emergency
• MassDEP COVID-19 FAQs for Public Water Suppliers
• Underground Storage Tank & Stage 1 Vapor Recovery Guidance During State of Emergency for COVID-19 Pandemic
• Guidance Regarding the Orders by the Governor Extending Certain Occupational and Professional Licenses

Motor Carrier Transportation

• Commercial Driver Information during State of Emergency
• Order Authorizing the Registrar of Motor Vehicles to Temporarily Extend Licenses, Permits, and other Identification Cards

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Michigan

Environment

• EGLE Establishes Process for Handling Enforcement Discretion Due to COVID-19
• EGLE and the Coronavirus FAQs

Motor Carrier Transportation

• Lifting of Certain Weight Restrictions
• Temporary relief from certain credentialing requirements for motor carriers transporting essential supplies, equipment, and persons

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Minnesota

Environment

• COVID-19 and Regulatory Flexibility

Motor Carrier Transportation

• Minnesota Emergency Executive Order 20-24 | FMCSA
• Waiver of safety regulations

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Mississippi

Environment

• Guidance to Regulated Community Regarding Compliance with Regulatory Requirements During the Motor Carrier COVID-19 Pandemic

Motor Carrier Transportation

• Mississippi Temporary COVID-19 Weight Increase for Carriers of Certain Commodities | FMCSA

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Missouri

Environment

• MDNR Policy on Enforcement Discretion
• Regulatory Relief

Motor Carrier Transportation

• Special Permit to Operate on Missouri Interstates
• Executive Order Suspending Hours of Service Requirements

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Montana

Environment

• Montana DEQ Compliance and Enforcement In Response to COVID-19

Motor Carrier Transportation

• Montana Waiver 3/30/20 | FMCSA
• Governor Directive to Implement FMCSA Emergency Declaration

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Nebraska

Environment

• Message on Compliance Expectations

Motor Carrier Transportation

• Nebraska DMV Waivers
• Nebraska Motor Carrier Safety Waivers

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Nevada

Environment

• Compliance during the COVID-19 Pandemic

Motor Carrier Transportation

• 90-Day Auto Extension for DMV Issued Documents
• COVID-19 Emergency Waiver

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New Hampshire

Environment

• NHDES Response to COVID-19

Motor Carrier Transportation

• Temporary Modification to Department of Safety Laws and Regulations

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New Jersey

Environment

• DEP Issues Guidance for Public Water Systems and Wastewater Monitoring, Licensed Operator and Certified Laboratory Issus due to the COVID-19 Pandemic
• Be Aware of Requirements to call the DEP Hotline
• Notice of Rule Waiver/Modification/Suspension Pursuant to Executive Order No. 103 (Pertains to underground storage tanks)
• General Guidance for Facilities and Contractors Maintaining Commercial Underground Storage Tanks
• Extensions for Monitoring and Emission Reports: Requirements for Air Quality Permits
• DEP Issues Guidance for Public Water Systems and Wastewater Monitoring, Licensed Operator and Certified Laboratory Issues Due to the COV?ID-19 Pandemic
• EMS COVID-19 Update
• Notice of Rule Waiver/Modification/Suspension Pursuant to Executive Order No. 103 (Pertaining to Remedial Actions)
• Solid Waste Temporary Rule Suspension
• General Guidance for Solid Waste & Recycling Collectors and Transporters and Processing, Transfer and Disposal Facilities and Temporary Adjustment of Limits and Discretionary Allowances
• Extension Guidelines for Water System Requirements During the COVID-19 Pandemic Established by the New Jersey Department of Environmental Protection-02
• Memorandum from Division of Water Quality re: March 31, 2020 USEPA Temporary Advisory for National Pollutant Discharge Elimination System Reporting in Response to COVID-19 Pandemic
• Division of Water Quality Sewage Sludge Management Advisory
• Reduced Monitoring Frequency for Sanitary Wastewater Discharges
• Temporary Rule Modification Pertaining to Medical Waste Generators
• COVID-19 Regulatory Compliance

Motor Carrier Transportation

• Weight Limit Waiver

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New Mexico

Environment

• SWQB COVID-19 Resources – Links to EPA Policy
• COVID-19: Air Quality Regulatory Notice for the Oil and Natural Gas Industry

Motor Carrier Transportation

• Executive Order Directing the New Mexico Department of Transportation to Create Emergency Expedited Special Permits

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New York

Environment

• Enforcement Discretion on Signature Procedures for Hazardous Waste and Low-Level Radioactive Waste Manifests and Non-Hazardous Waste Shipping Papers during the COVID-19 emergency
• Enforcement Discretion for Extension of Pesticide Applicator Recertification and Business and Agency Registration during the COVID-19 Emergency

Motor Carrier Transportation

• Emergency Declaration
• Emergency Waivers (does not include waivers related to CDL and drug & alcohol testing)
• COVID-19 information for customers and businesses
• In the matter of motor carrier compliance with regulations contained in Title 17 of the New York Codes, Rules and Regulations, (NYCRR) Parts 154-1 (Non-divisible Load Permits), Part 154-2 (Divisible Load Overweight Permits), and Part 820.1-820.13 except 820.2 (Commercial Driver Licensing and Drug/Alcohol Testing

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North Carolina

Environment

• State Environmental Enforcement during COVID-19

Motor Carrier Transportation

• NC Transportation Waivers
• Additional NC Transportation Waivers
• Facilitating Critical Motor Vehicle Operations

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North Dakota

Environment

• Temporary Environmental Compliance Policy
• Temporary Crude Oil Storage Vessels

Motor Carrier Transportation

• Executive Order Removing Weight Restrictions
• Expiration Dates Waived
• Highway Patrol: COVID-19 Federal Emergency Declaration and Waivers
• Weight Restrictions Lifted
• Extended Expiration Date for IRP Credentials

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Ohio

Environment

• Coronavirus Response, Questions and Guidance
• Extension of Solid Waste Reporting Deadlines

Motor Carrier Transportation

• Ohio 2020 PUCO HOS Expanded Coronavirus Relief 3-23-20 | FMCSA
• Ohio Relief for Fuel Trucks
• Ohio 2020 PUCO HOS Coronavirus Relief 3-13-2020 (final) | FMCSA

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Oklahoma

Environment

• Enforcement Discretion-Noncompliance Issues related to COVID-19 Pandemic

Motor Carrier Transportation

• Executive Department Seventh Amended Executive Order (Contains waivers of certain motor carrier rules for vehicles participating in relief efforts)

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Oregon

Environment

• DEQ Response to COVID-19

Motor Carrier Transportation

• Oregon Emergency Declaration, ATTN: Motor Carriers COVID-19 Emergency Declaration | FMCSA

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Pennsylvania

Environment

• DEP COVID-19 Update

Motor Carrier Transportation

• CDL Expiration Suspended
• Weight Restriction Exemptions

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Rhode Island

Environment

• DEM COVID-19 Updates

Motor Carrier Transportation

• Second Expiration Date Extensions Order

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South Carolina

Environment

• Environmental Regulatory Assistance 

Motor Carrier Transportation

• SC_Memo | FMCSA
• IRP and IFTA Changes

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South Dakota

Environment

• FAQs for COVID-19 and Water Quality

Motor Carrier Transportation

• South Dakota Executive Order

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Tennessee

Environment

• TDEC General Statement on COVID-19

Motor Carrier Transportation

• Tennessee exec-orders-lee19 | FMCSA

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Texas

Environment

• TCEQ Reporting Requirements for Regulated Entities - TCEQ - www.tceq.texas.gov
• General TCEQ Response to COVID-19

Motor Carrier Transportation

• Motor Carrier COVID-19 Information

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Utah

Environment

• Utah Division of Air Quality Regulatory Guidance During COVID-19 Pandemic
• Utah Division of Water Quality Regulatory Guidance During COVID-19 Pandemic
• Utah Division of Drinking Water Regulatory Guidance During COVID-19 Pandemic
• Utah Division of Waste Management and Radiation Control Regulatory Guidance During COVID-19 Pandemic
• Utah Division of Environmental Response and Remediation Regulatory Guidance During COVID-19 Pandemic

Motor Carrier Transportation

• No policy changes identified as of 5/3/2020

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Vermont

Environmental

• Enforcement and Compliance Guidance Document

Motor Carrier Transportation

• Vermont Gubernatorial Directive to the Vermont Department of Motor Vehicles | FMCSA

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Virginia

Environment

• COVID-19 Compliance and Enforcement Guidance

Motor Carrier Transportation

• Virginia DOT Waivers

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Washington

Environment

• Regulatory Flexibility

Motor Carrier Transportation

• Washington Memo 03/22/20 | FMCSA

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West Virginia

Environment

• Division of Air Quality, Compliance & Enforcement Bulletin COVID-19
• WVDEP still enforcing all applicable rules and regulations amid COVID-19 pandemic

Motor Carrier Transportation

• CDL and Medical Certificate Extensions

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Wisconsin

Environment

• COVID-19 Environmental Compliance Process

Motor Carrier Transportation

• Carrier Waivers
• Wisconsin emergency relief | FMCSA

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Wyoming

Environment

• COVID-19 Wyoming DEQ’s Temporary Guidance on Enforcement and Compliance Assurance Programs

Motor Carrier Transportation

• Emergency Declarations, Waivers, Exemptions and Permits | FMCSA
• Wyoming EO 2020-3 | FMCSA
• IRP Waivers
• FMCSR Waivers

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COVID-19 resource

Husch Blackwell has launched a COVID-19 response team providing insight to businesses as they address challenges related to the coronavirus outbreak. The page contains programming and content to assist clients and other interested parties across multiple areas of operations, including labor and employment, retailing, and supply chain management, among others.