Highlights of the North Carolina Manufacturers Alliance 2025 Environmental, Energy, Health & Safety School

The 2025 North Carolina Manufacturers Alliance’s (NCMA) Environmental, Energy, Health & Safety (EEHS) School, hosted in Raleigh, NC, provided timely and relevant EEHS presentations, panels, and discussions with leaders in industry, consulting, and government. Attendees of the school learned about the latest air regulatory updates, the latest water quality regulatory updates, workplace safety hot topics, and what’s new around energy and waste.

Regulatory and program highlights at the NCMA EEHS School regarding the latest activities at the United States Environmental Protection Agency (U.S. EPA), Occupational Safety and Health Administration (OSHA), the North Carolina Department of Environmental Quality (NCDEQ), and other relevant government bodies are summarized below.

Air Quality Regulatory Updates

U.S. EPA announced a long list of deregulatory actions in March 2025 that are currently the focus of their reduced staff. These include rolling back several greenhouse gas (GHG) regulations, the recently tightened fine particulate National Ambient Air Quality Standards (NAAQS), and several recent revisions to National Emission Standards for Hazardous Air Pollutants (NESHAP).

U.S. EPA is no longer focused on environmental justice (EJ)-related policies or actions. Each state may have its own EJ policy or rule.

U.S. EPA is currently ending the Good Neighbor Plan (the ozone transport federal implementation plan [FIP]) and advancing the concept of cooperative federalism by working with states on approvable State Implementation Plans (SIP) to address ozone transport.

The Congressional Review Act (CRA) was used to repeal 2024 revisions to two hazardous air pollutant (HAP) rules: 40 CFR Part 63, Subpart XXXX (Tire Manufacturing Maximum Achievable Control Technology [MACT] for mixing operations) and the Major MACT to Area (MM2A) provisions in 40 CFR Part 63, Subpart A. This was the first time the CRA has been used to repeal a Part 63 rule change, so the path forward is not clear.

U.S. EPA has rescinded its 2024 proposed revisions to the New Source Review (NSR) Rule provisions related to project emissions accounting (PEA).

NCDEQ is finalizing changes to their air curtain incinerator rules to provide support for Hurricane Helene recovery efforts.

Other NCDEQ proposed rules approved by the Environmental Management Commission (EMC) that are currently in the rulemaking process include:

• Permit issuance timelines rule (90 days for minor modifications and 270 days for major modifications).
• Pre-permitting construction activities rules at 15A NCAC 02Q .0114 (generally, construction activities you can undertake for a minor project prior to receiving your permit).
• Periodic rules review for 15A NCAC 02D (Air Pollution Control Requirements) and 15A NCAC 02Q (Air Quality Permits Procedures).

North Carolina Division of Air Quality (NCDAQ) is adding the following condition to permits: Disclosure of Information Relating to Emissions of Fluorinated Chemicals [15A NCAC 02Q .0308(a); 15A NCAC 02Q .0309(b)]:

The Permittee shall have an ongoing duty to disclose the presence of materials containing fluorinated chemicals at the facility that have the potential to result in the emission of fluorinated chemicals to the environment. Such disclosures shall be in writing and submitted to the Regional Office Supervisor within thirty days of the Permittee becoming aware of such information, unless such information has already been disclosed to NCDAQ by the Permittee. The disclosure shall describe the identity, quantity, and use of such material to the extent known. NCDAQ may require the permittee to conduct analysis or testing of fluorinated chemical emissions as necessary to properly evaluate emissions sources at the facility. As used in this condition, the term “fluorinated chemicals” includes but is not limited to per- and polyfluoroalkyl substances (PFAS).

Water Quality

Proposed groundwater standards for PFAS compounds have an effective date, if approved, of November 1, 2025 in 15A NCAC 02L .0200.

The interim maximum allowable concentrations (IMAC) for eight PFAS compounds in groundwaters were made effective October 15, 2024.

15A NCAC 02B .0512 (Direct Dischargers) and 15A NCAC 02H .0923 (Significant Industrial Users): PFOS, PFOA, and Gen X (PFAS) Monitoring and Minimization rules are due to be effective April 2026. The start of baseline monitoring will begin September 2026, and minimization plan implementation will be July 2029.

Energy

In 2024, the North Carolina Utilities Commission accepted the Duke Energy Consolidated Carbon Plan and Integrated Resource Plan (CPIRP). Duke proposed significant investments in solar, energy storage, and nuclear, more hydrogen-capable natural gas facilities, and 2,400 megawatts of offshore wind by 2035, saying this all-of-the-above strategy was needed to meet increased energy demand and keep costs low for customers, while enabling a transition out of coal to meet Executive Order No. 80.

Waste

North Carolina House Bill 600 amends North Carolina General Statue 130A-309.10 to ban the disposal of lithium-ion batteries in landfills. The effective date is December 1, 2026.

Workplace Health and Safety

Effective October 15, 2024, the OSHA Memo for Inspection Guidance for Animal Slaughtering and Processing Establishments established inspection guidance for North American Industry Classification System (NAICS) 3116.

Hazard Communication changes to the classification of health and physical hazards, and provisions related to labeling and safety data sheets will be effective January 1, 2025.

Effective January 13, 2025, changes to design and selection criteria of personal protective equipment (PPE) in the construction industry.

OSHA Part 1904 (Recordkeeping Policies and Procedures) Directive Number CPL 02-00-172 updated inspection procedures and policies will be effective January 13, 2025.

North Carolina minimum and maximum civil penalties associated with occupational safety and health standard violations increased will be effective July 1, 2025.

Effective July 17, 2025, OSHA Directive Number CPL 02-01-067 updates instructions on site-specific targeting and does not include construction worksites or public sector sites.

Conclusion

ALL4 is tracking state and federal regulatory developments related to these and other environmental, health, and safety (EHS) topics. If you have questions about how these regulatory changes might affect you or need help with EHS permitting and compliance in North Carolina, please reach out to Alex Ges at ages@all4inc.com or Claire Corta at ccorta@all4inc.com.