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About ELN
ELN Updates
Recent Federal Developments
TSCA/FIFRA
Deadline Approaching For Comments On EPA's Proposed Reporting Requirements For TSCA Mercury Inventory: As reported in our TSCAblog® item, on October 26, 2017, the U.S. Environmental Protection Agency (EPA) proposed triennial electronic reporting requirements pertinent to the supply, use, and trade of mercury in the United States. 82 Fed. Reg. 49564. The 2016 amendments to the Toxic Substances Control Act (TSCA) require EPA to establish periodic mercury reporting requirements for any person that manufactures mercury or mercury-added products or otherwise intentionally uses mercury in a manufacturing process to assist in the development of an inventory of mercury and other recommended actions. These other actions reportedly include potentially revising federal law or regulations to achieve further reductions in mercury use. Under the proposed rule, EPA proposes to require reporting on the manufacture, import, distribution in commerce, storage, and export of mercury. EPA is directed by new TSCA to refrain from requiring reporting related to the generation, handling, or management of mercury-containing waste, unless mercury is recovered in the management of such waste. The proposed rule aims to narrow data gaps and limitations encountered in EPA's historic reliance on publicly available data on the mercury market in the United States. Additionally, the information provided under the proposed rule would be used by the U.S. government to assist in its implementation of the Minamata Convention, a multilateral environmental agreement that addresses the supply, use, and trade in mercury. Comments on the proposal are due by December 26, 2017.
EPA Issues Determination On Small Manufacturers Under TSCA Section 8: On November 30, 2017, EPA issued a notice of its final determination on whether revision to the current size standards for small manufacturers and processors, which are used in connection with reporting regulations under TSCA Section 8(a), is warranted. 82 Fed. Reg. 56824. The notice states that EPA has made its final determination that revision is warranted based upon several factors. EPA states in the notice that it preliminarily determined that a revision to the size standards is warranted "[?b]ecause of the magnitude of the increase in the [Producer Price Index (PPI)] since the last revision of the size standards and because the current annual sales standard is comparatively low given current revenue-based size standards developed by [the Small Business Administration (SBA)]." When EPA reviewed the change in the PPI for Chemicals and Allied Products between 1988 and 2015, it found that the PPI has changed by 129 percent, which far exceeds the 20 percent inflation index specified as a level above which EPA may adjust annual sales levels in the current standard if deemed necessary.
EPA also based its determination on a review of the comments on the preliminary determination. EPA states that most commenters agreed with its preliminary determination that an update is warranted and several also provided their opinions on how the standards should be revised. EPA states the actual changes to the standards were out of the scope of this determination, but it will address those issues in the subsequent proposed rulemaking.
Finally, EPA relied upon feedback from consultation with the SBA. SBA's Office of Advocacy substantively agreed with EPA's preliminary determination (that a revision to the current size standards is warranted), but it had requested EPA to consider additional factors in reaching that conclusion, which EPA did not. Specifically, the SBA wanted EPA to consider whether the standard is structured appropriately, and wanted EPA to evaluate a broader set of factors related to firm and industry characteristics and percentage of firms impacted by Section 8 rules. More information on these standards is available in our blog item under key phrase size standards.
EPA Extends Comments On Use Information Of PBT Chemicals: EPA issued a memorandum dated December 4, 2017, extending the comment deadline to collect information on five persistent, bioaccumulative, and toxic (PBT) chemicals (the memorandum is posted in each docket). EPA requested information on uses, products containing these chemicals, exposed populations, and alternatives to these chemicals. These five chemicals were selected on October 11, 2016, to receive expedited action under TSCA Section 6(h) as amended by the Frank R. Lautenberg Chemical Safety for the 21st Century Act, which requires EPA to take expedited regulatory action to address risks from certain PBT chemicals. The five chemicals and their corresponding dockets are:
Decabromodiphenyl ethers (DecaBDE), used as a flame retardant in textiles, plastics, and polyurethane foam — Docket ID No. EPA-HQ-OPPT-2016-0724;
Hexachlorobutadiene (HCBD), used in the manufacture of rubber compounds and lubricants and as a solvent — Docket ID No. EPA-HQ-OPPT-2016-0738;
Pentachlorothiophenol (PCTP), used as an agent to make rubber more pliable in industrial uses — Docket ID No. EPA-HQ-OPPT-2016-0739;
Phenol, isopropylated, phosphate (3:1), used as a flame retardant in consumer products and other industrial uses — Docket ID No. EPA-HQ-OPPT-2016-0730; and
2,4,6-Tris(tert-butyl)phenol, used as a fuel, oil, gasoline, or lubricant additive — Docket ID No. EPA-HQ-OPPT-2016-0734.
In August 2017, EPA provided background information for each of the five PBT chemicals in the form of use documents that provide a preliminary summary of available information collected by EPA on the manufacturing (including importing), processing, distribution in commerce, use, and disposal of each chemical. Amended TSCA gives EPA three years to propose rules to reduce risks and exposures from these PBT chemicals to the extent practicable (until June 22, 2019), and EPA must issue the rules in final within 18 months of when they are proposed. More information on the PBTs is available on our blog under keyword PBTs. The deadline to submit comments is now January 12, 2018.
EPA Withdraws Direct Final Rule On Formaldehyde Emission Standards For Composite Wood Products: On December 8, 2017, EPA withdrew its direct final rule published on October 25, 2017, to update the voluntary consensus standards that originally were published under the TSCA Title VI formaldehyde emission standards for composite wood products final rule on December 16, 2016. 82 Fed. Reg. 57874. In the direct final rule and proposed rule, EPA amended the testing requirements for panel producers and third-party certifiers establishing correlation between approved quality control test methods and either the ASTM E1333-14 test chamber, or, upon showing equivalence, the ASTM D6007-14 test chamber. As noted in the direct final rule, if EPA received adverse comment on the proposed amendments, EPA would publish a timely withdrawal of the direct final rule in the Federal Register informing the public that the direct action will not take effect. EPA received adverse comment on the proposed rule amendments, and is therefore withdrawing the direct final rule and will instead proceed with a final rule based on the proposed rule after considering all public comments.
RCRA/CERCLA/CWA/CAA/EPCRA
"Waters Of The U.S." (WOTUS) Developments: Two-Step Rulemaking Now Has A "Step Zero": On November 22, 2017, EPA and the U.S. Army Corps of Engineers (Corps) issued a proposal to add an applicability date to the 2015 Clean Water Rule (CWR) entitled "Definition of 'Waters of the United States' – Addition of an Applicability Date to 2015 [CWR]" (Proposed Rule or Step Zero) in the Federal Register. 82 Fed. Reg. 55542. The Proposed Rule complements the EPA/Corps ongoing two-step rulemaking process to rescind and replace the CWR, which re-defined WOTUS for the purposes of clarifying the boundaries of Clean Water Act (CWA) jurisdiction over the nation's rivers, streams, and wetlands.
The U.S. Court of Appeals for the Sixth Circuit stayed implementation of the CWR nationwide shortly after it went into effect in late 2015, however, the CWR regulatory text currently remains in the Code of Federal Regulations (C.F.R.) pending final action on the proposed rescission and replacement with the pre-existing WOTUS definition language (Step One). With Step Zero, EPA/Corps aim to "maintain the legal status quo and thus provide continuity and certainty for regulated entities, the States and Tribes, agency staff, and the public." The Proposed Rule would not create any new regulatory obligations; rather it would amend the text of the C.F.R. to add an applicability date two years from the date of final action on this proposal. The brief comment period for the Proposed Rule closed on December 13, 2017.
In pursuing this additional regulatory step, EPA/Corps are aiming to circumvent potential regulatory confusion and legal workload that would ensue if the U.S. Supreme Court invalidates the Sixth Circuit's jurisdiction in the CWR litigation, which would have the effect of lifting the current nationwide stay. The parties' venue dispute turns on the Court's interpretation on CWA Section 509(b), which sets forth the circumstances where CWA challenges should be brought directly to the U.S. Courts of Appeal. The Court heard oral arguments on October 11, 2017, and is expected to issue its ruling in late 2017/early 2018. More background on the CWR and the two-step rulemaking is available in this Bergeson & Campbell, P.C. (B&C®) blog post.
EPA Withdraws CERCLA Hardrock Mining Rule: On December 1, 2017, EPA announced that it will not issue final regulations under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund) for certain hardrock mining facilities. "After careful analysis of public comments, the statutory authority, and the record for this rulemaking, EPA is confident that modern industry practices, along with existing state and federal requirements address risks from operating hardrock mining facilities," stated EPA Administrator Scott Pruitt. "Additional financial assurance requirements are unnecessary and would impose an undue burden on this important sector of the American economy and rural America, where most of these mining jobs are based," he added. EPA proposed regulations under CERCLA Section 108(b) on January 11, 2017. 82 Fed. Reg. 3388. EPA stated that it has decided not to issue final regulations because the risks associated with these facilities' operations are addressed by existing federal and state programs and industry practices. EPA was under a court-ordered deadline to take final action on this rulemaking by December 1, 2017.
EPA Releases List Of Superfund Sites Requiring "Immediate And Intense Attention": EPA on December 8, 2017, released a list of 21 Superfund and other hazardous waste sites that will require "immediate and intense attention." The list includes sites in all ten EPA regions and was created in response to the Superfund Task Force Recommendations, issued this summer. In developing this initial list, EPA considered sites that can benefit from Administrator Pruitt's direct engagement and have identifiable actions to protect human health and the environment. These are sites requiring timely resolution of specific issues to expedite cleanup and redevelopment efforts. The list is designed to spur action at sites where opportunities exist to act quickly and comprehensively. The list is also intended to be dynamic. Sites will move on and off the list as appropriate. At times, there may be more or fewer sites based on where the Administrator's attention and focus is most needed. There is no commitment of additional funding associated with a site's inclusion on the list. The list is available online. EPA also issued a question and answer document accompanying the list.
EPA Issues Final Volume Requirements Under RFS: On December 12, 2017, EPA issued a final rule establishing volume requirements under the Clean Air Act's (CAA) Renewable Fuel Standard (RFS) program for 2018 for cellulosic biofuel, biomass-based diesel (BBD), advanced biofuel, and total renewable fuel, and biomass-based diesel for 2019. 82 Fed. Reg. 58486. The final volume requirements are listed in the table below.
Final Volume Requirementsa
Cellulosic biofuel (million gallons) 288 n/a
Biomass-based diesel (billion gallons) 2.1b 2.1
Advanced biofuel (billion gallons) 4.29 n/a
Renewable fuel (billion gallons) 19.29 n/a
a All values are ethanol-equivalent on an energy content basis, except for BBD which is biodiesel-equivalent.
b The 2018 BBD volume requirement was established in the 2017 final rule, (81 FR 89746; December 12, 2016).
The final rule is effective on February 12, 2018.
EPA Releases Science Assessment For Sulfur Oxides NAAQS: EPA on December 13, 2017, announced the availability of a final document titled "Integrated Science Assessment for Sulfur Oxides — Health Criteria." 82 fed. Reg. 58600. The document was prepared by the National Center for Environmental Assessment (NCEA) within EPA's Office of Research and Development (ORD) as part of the review of the primary (health-based) National Ambient Air Quality Standards (NAAQS) for sulfur oxides. This Integrated Science Assessment (ISA) provides a comprehensive review, synthesis, and evaluation of the most policy-relevant science to serve as the scientific foundation for EPA's review of the current primary NAAQS for sulfur oxides. The document is available online.
EPA Offers Free Workshop On Hazardous Waste Generator Improvements Rule: EPA's Office of Resource Conservation and Recovery (ORCR) will hold a full-day workshop on the 2016 Hazardous Waste Generator Improvements Final Rule. The workshop will be held on Wednesday, February 7, 2018, in Arlington, VA, from 8:30 to 3:00 p.m. It is free for all participants. Registration is available online. The workshop will cover all the major provisions of the rule, looking at regulatory text and common implementation questions that have come up since the rule was issued in final. Specifically, the training examines provisions changed by the rule for hazardous waste determinations, counting hazardous waste, marking and labeling, episodic generation, very small quantity generator (VSQG) waste consolidation at large quantity generators (LQG), satellite accumulation areas, emergency planning and preparedness, closure, recordkeeping, and reporting using the updated site identification form. The workshop will be held at EPA's Conference Center in the Potomac Yard building in Arlington, VA. If there is sufficient interest in this training, EPA stated that it will look into offering another in the DC Metro area at a later date.
FDA Releases Draft Guidance On Best Practices For Convening A GRAS Panel: On November 16, 2017, the U.S. Food and Drug Administration (FDA) announced that it was releasing a draft guidance for industry entitled "Best Practices for Convening a GRAS Panel." 82 Fed. Reg. 53433. FDA states that the draft guidance document is intended for any person who is responsible for a conclusion that a substance may be used in food on the basis of the generally recognized as safe (GRAS) provision of the Federal Food, Drug, and Cosmetic Act (FFDCA) when that person convenes a panel of experts (GRAS panel) to evaluate independently whether the available scientific data, information, and methods establish that the substance is safe under the conditions of its intended use in human food or animal food. To ensure that all comments on this draft guidance are considered before it issues the final version of the guidance, FDA is requesting comments by May 15, 2018; for comments related to the collection of information provisions in the draft guidance, FDA is requesting comments by January 16, 2018.
FDA Releases Small Entity Compliance Guide For FSMA Sanitary Transportation Rule: On November 22, 2017, FDA announced that it was releasing a guidance for industry entitled "Sanitary Transportation of Human and Animal Food: What You Need to Know About the FDA Regulation — Small Entity Compliance Guide." 82 Fed. Reg. 55503. FDA states this Small Entity Compliance Guide (SECG) will assist small businesses understand the requirements of the Final Rule on the Sanitary Transportation of Human and Animal Food (Sanitary Transportation Rule) promulgated under the Food Safety Modernization Act (FSMA). In the guide, shippers, loaders, carriers, and receivers covered by the Sanitary Transportation Rule will find descriptions of the rule requirements in an easy-to-read question and answer format that includes information on topics such as training and recordkeeping. FDA is accepting comments on the guidance. Small businesses have until April 6, 2018, to comply with the Sanitary Transportation Rule.
FDA Working To Address Concerns About Regulation Of Human Food By-products Used For Animal Food: On November 27, 2017, FDA announced its desire to work with industry to address concerns about the regulation of human food by-products used for animal food, and that it is considering approaches that balance practical and public health considerations. FDA's Frequently Asked Questions on the FSMA web page states this question (PC.20 under the Preventive Controls Rules: Human Food and Animal Food tab): "Do the preventive controls requirements apply to human food by-products for use in animal food that are dried, frozen or slightly modified specifically to facilitate storage and transportation?" In response, FDA states that several sectors of the food industry "have expressed concern about having to meet preventive controls requirements for certain other activities performed on their human food by-product and have asked that FDA consider streamlining the requirements for other activities that are also commonly performed to facilitate the storage and transportation of their by-products, including commingling ingredients, evaporating, chopping, mechanical mixing, pressing, trimming and washing." Further, FDA "takes these concerns seriously and understands the practical value of these activities in preparing human food by-products for storage and transportation," "recognize[s] the need to balance how these requirements impact current industry practices and the need to protect human and animal health," and is "committed to working with industry to address these concerns, and are considering approaches that balance practical and public health considerations." FDA states that it will not be "conducting routine regulatory inspections of compliance with the animal food preventive controls requirements until the fall of 2018," and this delay in routine regulatory inspections "includes inspection of human food by-products that are further processed and required to comply with the animal food preventive control requirements."
FDA Creates Produce Safety Network To Support Implementation Of Produce Safety Rule: On December 6, 2017, FDA announced the establishment of the Produce Safety Network (PSN). The PSN is intended to support the efforts of farmers, state regulators, and other key stakeholders to implement the FSMA final rule on produce safety, which is aimed at preventing foodborne illnesses associated with produce. The PSN establishes regionally-based policy and regulatory experts throughout the country, making them uniquely suited to address the issues specific to the states they are supporting and places these experts, from two very different FDA offices, within one team. The network combines the regulatory expertise from the FDA's Office of Regulatory Affairs (ORA) with the policy and science expertise from FDA's Center for Food Safety and Applied Nutrition (CFSAN). More information on the PSN is available on FDA's website.
IFSAC Issues Paper On Categorization Of Foods Linked To Foodborne Disease Outbreaks: On December 8, 2017, FDA issued a Constituent Update in which it announced that new research from scientists with the Interagency Food Safety Analytics Collaboration (IFSAC) (a collaboration between FDA, the Centers for Disease Control and Prevention (CDC), and the Food Safety and Inspection Service (FSIS) of the U.S. Department of Agriculture (USDA)) on how to categorize foods linked to foodborne disease outbreaks was recently published in a paper in the journal Foodborne Pathogens and Disease: "An Updated Scheme for Categorizing Foods Implicated in Foodborne Disease Outbreaks: A Tri-Agency Collaboration." FDA states that this paper updates previous food categories used by CDC and has five levels with subcategories at each level, for a total of 234 food categories. Highlights of the IFSAC food categorization scheme include:
Close alignment with the food product definitions used by FDA and FSIS for regulatory purposes;
Separation of aquatic animals, land animals, and plant foods into increasingly specific animal or botanical food categories; and
Separation of foods based on food processing, preparation, and consumption type.
FDA Releases Draft Guidance On Refusal Of Inspection By A Foreign Food Establishment Or Foreign Government: On December 12, 2017, FDA released a draft guidance for industry entitled "Refusal of Inspection by a Foreign Food Establishment or Foreign Government." 82 Fed. Reg. 58410. FDA states that this draft guidance, when issued in final, will "provide information for foreign food establishments subject to [its] inspection, as well as foreign governments, on when [it] may consider that a foreign food establishment or a government of a foreign country has refused to permit an inspection by [FDA] as provided in the [FFDCA]." To ensure that all comments on this draft guidance are considered before it issues the final version of the guidance, FDA is requesting comments by February 26, 2018.
EC Posts Comments Received On Draft Regulation To Amend REACH Annexes To Address Nanomaterials: As reported in our October 11, 2017, blog item, on October 9, 2017, the European Commission (EC) began a public consultation on a draft regulation that would amend Annexes I, III, VI, VII, VIII, IX, X, XI, and XII of the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulation to address nanoforms of substances. Comments were due November 6, 2017. The EC has posted the comments online. In all, 36 comments were submitted. The comments received fall into the following categories: business associations; public authorities; non-governmental organizations; company/business organizations; environmental organizations; academic/research institutions; and other.
EC Publishes Report On Ecosystem To Accelerate Uptake Of Innovation In Materials Technology: In October 2017, the EC Directorate-General for Research and Innovation published a report entitled An ecosystem to accelerate the uptake of innovation in materials technology: Report by the High Level Group of EU Member States and Associated Countries on Nanosciences, Nanotechnologies and Advanced Materials. The High Level Group of European Union (EU) Member States and Associated Countries on Nanosciences, Nanotechnologies and Advanced Materials examined the barriers and obstacles that need to be addressed to accelerate the industrial uptake of nanotechnologies and advanced materials. It agreed on a list of potential actions that the EU Member States and associated countries may carry out in four key areas for upscaling: characterization, modeling translation, pilots, and safety.
Germany Publishes Report On Relationship Of Nanomaterial's Physical-Chemical Properties And Aquatic Toxicity For The Purpose Of Grouping: Germany's Federal Environment Agency (UBA) published a November 2017 report entitled Considerations about the relationship of nanomaterial's physical-chemical properties and aquatic toxicity for the purpose of grouping. The project objective was to correlate physical-chemical data with ecotoxicological effects for selected nanomaterials and to define reference values that can serve as a basis for grouping. The report presents the development of concepts for the grouping of nanomaterials with regard to their ecotoxicological effects, focusing on aquatic ecotoxicity.
INRS 2016/2017 Brochure Includes Studies In Progress Concerning Manufactured Nanomaterials: On November 23, 2017, the French National Research and Safety Institute for the Prevention of Occupational Accidents and Diseases (INRS) published a report summarizing studies and research completed in 2016 and in progress in 2017. In 2016, INRS completed a study entitled "Impact of sources and of the environment on confinement of nanoparticulate pollutants by collective protective equipment." The objective of the study was to develop the tools necessary for assessing the effectiveness of collective protection systems, based on ventilation, for protecting people from nanoparticle aerosols. According to INRS, the results made it possible to identify the main nanomaterial aerosol sources present in ventilated enclosures.
ISO Publishes Standard On Aquatic Toxicity Assessment Of Manufactured Nanomaterials In Saltwater Lakes: In November 2017, the International Organization for Standardization (ISO) published standard ISO/TS 20787:2017, "Nanotechnologies — Aquatic toxicity assessment of manufactured nanomaterials in saltwater lakes using Artemia sp. Nauplii." ISO/TS 20787:2017 specifies a test method, aiming to maximize repeatability and reliability of testing, to determine whether manufactured nanomaterials are toxic to aquatic organisms, specifically Artemia sp. nauplius. ISO states that ISO/TS 20787:2017 is applicable to manufactured nanomaterials that consist of nano-objects such as nanoparticles, nanopowders, nanofibers, nanotubes, and nanowires, as well as aggregates and agglomerates of such manufactured nanomaterials.
NNI Publishes Supplement To President's 2018 Budget Request: On November 30, 2017, the National Nanotechnology Initiative (NNI) published a supplement to the President's 2018 budget. The supplement also serves as NNI's annual report and summarizes the progress made in achieving NNI's goals, the research and development (R&D) activities and plans of the participating agencies, and the agency investments in each program component area. The President's 2018 Budget requests $1.2 billion for the NNI, "a continued investment in support of innovation promoting America's competitiveness, economic growth, and national security." The NNI investments proposed for 2018 reflect an emphasis on broad, fundamental research in nanoscience to provide a continuing pipeline of new discoveries that will enable future transformative commercial products and services.
RIVM Takes Critical Look At EUON: The Dutch National Institute for Public Health and the Environment (RIVM) published a brochure entitled "The European Union Observatory for Nanomaterials: A step forward?" on November 30, 2017. While the EUON collects the available information in one central location, the quality of the information is also important. RIVM states that one of the sources of information is REACH, but notes that "this risk assessment framework is not yet sufficiently suitable for nanomaterials." In addition, according to RIVM, the information is limited to broad categories of products and articles, and brand names are not specified. RIVM concludes that "it will remain difficult for consumers, as well as others, to judge whether they are actually using a 'nanoproduct' and what the potential health consequences are of such use. Accordingly, even though the EUON maintains a separate web portal for consumers, it appears most relevant for experts, competent authorities, and industry."
Presentations Available From ECHA Webinar On REACH Guidance For Nanomaterials: On November 30, 2017, the European Chemicals Agency (ECHA) held a webinar to explain the support documentation available for registrants that cover nanoforms in their REACH registration dossier. The main focus was on the registration and read-across of nanoforms, but the webinar also covered updates for information requirements for human health and the environment. ECHA has posted the presentations from the webinar.
UBA Report Summarizes Work To Develop New OECD Test Guideline On Dispersion Stability Of Nanomaterials: In December 2017, UBA published a report entitled Clarification of methodical questions regarding the investigation of nanomaterials in the environment: Development of a decision support tool for the investigation of nanomaterial's environmental behaviour based on dispersion behaviour and dissolution in relation to various environmental parameters. The aim of the project was to develop a standardized test method to determine dispersibility and dispersion stability of nanomaterials in simulated environmental media as a new Organization for Economic Cooperation and Development (OECD) Test Guideline. The test method developed was submitted to OECD by UBA and published by OECD in October 2017 as a new "Test Guideline on dispersion stability of nanomaterials in simulated environmental media (OECD No. 318)." The final report describes the considerations, experimental approaches, and obtained results that build the basis for the new OECD Test Guideline.
Sweden Announces Product Registration Requirement For Nanomaterials: On December 5, 2017, the Swedish Chemicals Agency (KEMI) announced that it has amended the information requirements for the products register to require notifiers to provide information on nanomaterials contained in chemical products. The announcement, available in Swedish, states that the requirement will enter into force on January 1, 2018, and the first reports will be due in February 2019. As reported in our June 13, 2017, blog item, on June 7, 2017, Sweden notified the draft regulation to the EC. Under the draft regulation, the requirement will apply to nanomaterials that have been intentionally added to the product, regardless of the concentration of the nanomaterials. The definition of nanomaterial will reflect the EC's recommended definition, except that nanomaterials that are natural or incidental shall not be notified to the product register. Exemption from the notification obligation is proposed for nanopigments and for entities with an annual turnover of less than SEK 5 million.
WHO Publishes Guidelines On Protecting Workers From Potential Risks Of Manufactured Nanomaterials: In December 2017, the World Health Organization (WHO) published WHO Guidelines on Protecting Workers from Potential Risks of Manufactured Nanomaterials. The Guideline Development Group (GDG) used a precautionary approach as one of its guiding principles, as well as the hierarchy of controls. The recommendations include:
Assess health hazard of manufactured nanomaterials;
Assess exposure to manufactured nanomaterials; and
Control exposure to manufactured nanomaterials.
The GDG states that it cannot make a recommendation for targeted manufactured nanomaterial-specific health surveillance programs over existing health surveillance programs that are already in use owing to the lack of evidence. According to the Guideline, the GDG considers training workers and worker involvement in health and safety issues to be best practice, but cannot recommend one form of training of workers over another, or one form of worker involvement over another, owing to the lack of studies available. The Guideline states: "It is expected that there will be considerable progress in validated measurement methods and risk assessment. Therefore, the GDG proposes to update these guidelines in five years' time, in 2022."
BIOBASED/RENEWABLE PRODUCTS
BRAG Biobased Products News And Policy Report: B&C consulting affiliate, B&C® Consortia Management, L.L.C. (BCCM), manages the Biobased and Renewable Products Advocacy Group (BRAG®). For access to a weekly summary of key legislative, regulatory, and business developments in biobased chemicals, biofuels, and industrial biotechnology, go to https://www.braginfo.org.
Senate EPW Committee Approves CEQ And EPA Leadership Nominations: On November 29, 2017, the Senate Environment and Public Works (EPW) Committee approved the nomination of Kathleen Hartnett White to serve as Director of the Council on Environmental Quality (CEQ). The Committee also approved the nomination of Andrew Wheeler as Deputy Administrator of EPA. Both votes were along party lines (11-10). White currently serves as Distinguished Senior Fellow for energy and the environment at the Texas Public Policy Foundation (TPPF). From 2001 to 2007, Wheeler was Chairwoman and Commissioner of the Texas Commission on Environmental Quality (TCEQ). White also served as a Director of the Lower Colorado River Authority, the Texas Water Development Board, the Environmental Flows Advisory Group, the Texas Strategic Economic Development Planning Commission, and the Texas Emissions Reduction Advisory Board. Wheeler is a principal and the head of the energy and the environment team at Faegre Baker Daniels Consulting. Wheeler co-chairs the energy and natural resources industry team within the law firm. Prior to joining Faegre Baker Daniels, Wheeler worked at the U.S. Senate EPW Committee for 14 years serving in various roles, including as the Majority and Minority Staff Director and Chief Counsel. Wheeler started his career at EPA as a Special Assistant in the Toxics Office where he received three bronze medals. Wheeler has a B.A. from Case Western Reserve University, a J.D. from Washington University in St. Louis, and an M.B.A. from George Mason University.
House Passes Bill Reauthorizing And Amending Brownfields Program: On November 30, 2017, the House overwhelmingly approved a bill toreauthorize the CERCLA brownfields program. By a vote of 409-8, the House approved the Brownfields Enhancement, Economic Redevelopment, and Reauthorization Act of 2017 (H.R. 3017). This is the first time in 15 years that lawmakers have reauthorized the brownfields program. The bill is an amalgam of H.R. 3017, introduced by Representative David McKinley (R-WV), and H.R. 1758, introduced by Representative Elizabeth Esty (D-CT). The bill provides $200 million in funding for the program for fiscal years (FY) 2017 through 2021 under CERCLA Section 104(k). It also authorizes $50 million for state response grants at current levels for FY 2017 through 2021 under Section 128(a) of CERCLA. The bill amends the definition of "owner or operator" in Section 101(20)(D) of CERCLA by removing the term "involuntarily." This means that a unit of state or local government that acquires ownership or control involuntarily is not an "owner or operator" under CERCLA. The bill also makes a conforming change in the definition of "contractual relationship" in CERCLA Section 101(35)(D). The bill seeks to enhance redevelopment of petroleum brownfield sites. It seeks to do so by amending the definition of "brownfield site" in CERCLA Section 101(39)(D) to clarify that a petroleum site is eligible to be a brownfield site if there is no viable responsible party and if EPA or the state determine that the site will be assessed and remediated by a person who is not potentially liable to clean up the site. The bill clarifies the existing definition of a "bona fide prospective purchaser" in Section 101(40) of CERCLA with respect to a tenant or person who holds a lease hold interest, but who otherwise meets the requirements to be a bona fide prospective purchaser. Expanded eligibility for nonprofit organizations is also included in the bill. It clarifies that certain non-profit entities 501(c)(3) organizations, limited liability corporations and limited liability partnerships (the members of which are non-profit organizations), and qualified community development entities are "eligible entities" under CERCLA Section 104(k)(1).
House Energy And Commerce Committee Approves Seven Energy And Environmental Bills: The House Energy and Commerce Committee on December 6, 2017, advanced seven environmental and energy bills. The Committee approved: H.R. 1733, which would require the Department of Energy to review and update a report and submit to Congress a coordinated federal strategy to increase the beneficial reuse of use lubricating oil; H.R. 2872, a bill that would promote hydropower development at existing non-powered dams by providing the Federal Energy Regulatory Commission (FERC) with the discretion to grant exemptions from license requirements for qualifying facilities; H.R. 2880, a bill that would promote closed-loop pumped storage hydropower development by limiting FERC's authority to only impose licensing conditions that are necessary to protect public safety, or are reasonable, economically feasible, and essential to protect fish and wildlife resources; H.R. 350, which would clarify that the anti-tampering provisions applicable to motor vehicles do not apply to vehicles used solely for competition; H.R. 453, a bill to extend the deadlines for the second phase of new source performance standards for new residential wood heaters; H.R. 1119, a bill to provide alternative compliance options with the Cross-State Air Pollution Rule and Mercury and Air Toxic Standards for coal refuse-to-energy plants; and H.R. 1917, which would extend the deadlines for the National Emission Standards for Hazardous Air Pollutants for brick and structural clay products manufacturing or clay ceramics manufacturing. The extension would last until judicial reviews of the rules are completed.
Senate Committee Holds Hearing On Superfund Program: On December 6, 2017, the Senate EPW Subcommittee on Superfund, Waste Management, and Regulatory Oversight concluded a hearing to examine challenges facing Superfund and waste cleanup efforts following natural disasters. The Committee received testimony from Bryan W. Shaw, TCEQ Chairman, Austin; Matthew Rodriquez, California Environmental Protection Agency Secretary, Sacramento; and Tracy Hester, University of Houston Law Center, Houston, Texas. Committee member statements, witness testimony, and a webcast of the hearing are available online.
Senate Approves Susan Bodine As EPA Assistant Administrator For Enforcement: The Senate on December 7, 2017, by voice vote approved Susan Parker Bodine to be the Assistant Administrator of EPA's Office of Enforcement and Compliance Assurance. Ms. Bodine is Chief Counsel for the Senate Committee on EPW, a position she has held since January 2015. Ms. Bodine's nearly 29 years of environmental law experience includes both government service and private practice. Ms. Bodine served in the George W. Bush Administration as the Assistant Administrator of EPA's Office of Solid Waste and Emergency Response. Prior to that, Ms. Bodine was Staff Director and Counsel for the Subcommittee on Water Resources and Environment of the House Committee on Transportation and Infrastructure. She also was an associate at Covington & Burling and a partner at Barnes & Thornburg. Ms. Bodine's undergraduate degree is from Princeton University and her law degree is from the University of Pennsylvania School of Law.
Senate Committee Approves Nomination Of Scott Mugno To Head OSHA: The Senate Health, Education, Labor, and Pensions Committee on December 13, 2017, approved the nomination of Scott Mugno to be Assistant Secretary of Labor for the Occupational Safety and Health Administration (OSHA).Mr. Mugno is currently the Vice President for Safety, Sustainability and Vehicle Maintenance at FedEx Ground and also served as the Managing Director for FedEx Express Corporate Safety, Health and Fire Protection. Mungo's responsibilities in both those positions included developing, promoting, and facilitating the safety and health program and culture. Mugno was twice awarded FedEx's highest honor for his safety leadership at FedEx Express. Prior to FedEx, Mugno was a Division Counsel at Westinghouse Electric Corporation's Waste Isolation Division and Deputy Staff Judge Advocate for the Eastern Region U.S. Army Military Traffic Management Command. Mungo also held other legal positions in the U.S. Army Judge Advocate General (JAG) Corps at the 24th Infantry Division at Fort Stewart, Georgia, and in small private–practice law firms before joining the U.S. Army JAG Corps.
EPA Semi-Annual Regulatory Agenda Released: On December 14, 2017, EPA released the most recent version of its semi-annual regulatory agenda. The agenda details the status of the regulatory actions currently under development at EPA. The agenda is available online.
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Proposed Amendments to the Hazardous Products Regulations in Canada – Update from Bergeson & Campbell, P.C.
Final Risk Evaluation for 1,4-Dioxane Finds Unreasonable Risk to Workers for Certain Uses – Update from Bergeson & Campbell, P.C.
2021 Environmental and Energy Law Forecast – Update from Manko Gold Katcher Fox
EPA Issues Final Rule Intended to Strengthen Transparency in Pivotal Science – Update from Bergeson & Campbell, P.C.
2021 Forecast for U.S. Federal and International Chemical Regulatory Policy – Update from Bergeson & Campbell, P.C.
Biobased Products News and Policy Report – Update from Bergeson & Campbell, P.C.
EPA Publishes Final Risk Evaluation for Asbestos, Part 1: Chrysotile Asbestos – Update from Bergeson & Campbell, P.C.
Twenty-One of ELN's member law firms were recognized as The Best Lawyers in America and U.S. News Best Law Firms.
Proposed TSCA Fees Rule Intended to Increase Flexibility and Reduce Burdens – Bergeson & Campbell, P.C.
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Competitive Reality & Game Shows
The Chefs/Cheftestants of Top Chef
By Veruca Assault, April 29, 2014 in Top Chef
cooksdelight 54.4k
I was watching that, and questioned why he added garlic to the ramps. Peeeuuuuwwwwwww!
AriAu 2.8k
Fabio sighting last night at his new place, Bar Siena, in Chicago's West Loop, right across the street from Stephanie Izard's Little Goat Dinner and a stones throw from The Girl and the Goat. He was walking out around 8pm while we were enjoying the weather while waiting for our table. He gave us a wave but seemed to be in a hurry.
Place has been open a little over a week and the food was pretty good. Yes, there is gnocchi, but we had the gnudi instead and it was the only thing that wasn't under-seasoned, something that was surprising for me since it was Fabio!
Edited August 5, 2015 by AriAu
Message from Cat Cora:
In Los Angeles International Airport (LAX) waiting for my flight on my way with CARE and three amazing chefs, Chef Carla Hall, Chef Antonia Lofaso, and Spike Mendelsohn for this life changing trip up Mozambique. Follow our journey on Instagram and Twitter with the hashtag #ChefsTable!
They are on a humanitarian mission for CARE. Looking forward to updates. :)
Nysha 21.8k
So, is Spike not a chef?
He's a restaurant owner, I just quoted word-for-word what Cat said.
HyeChaps 1.7k
What Jamie is doing now:
http://www.tvinsider.com/article/34656/what-i-do-jamie-lauren-supervising-culinary-producer/
Tiffani Faison getting some really good press!
http://www.boston.com/food-dining/restaurants/2015/08/22/zagat-says-watch-out-for-top-chef-alumn-new-boston-restaurant/ji0QAa6Q6KLdnSAjDldkgP/story.html
About Kevin Sbraga: http://philadelphia.suntimes.com/phi-entertainment/7/96/188662/top-chef-kevin-sbraga-Philadelphia/
Ouch! Hadn't heard that one about Kevin.
ProudMary 7.2k
Mike Isabella and Jennifer Carroll are partnering a French Mediterranean restaurant.
http://glamorosi.blogspot.com/2015/08/979-Top-Chef-Mike-Isabella-Jennifer-Carroll-Restaurant.html
Jen finally gets a restaurant!
Yigit Pura, winner of Top Chef Just Desserts, is looking for extras if you live in San Francisco:
TV people… last chance to sign up to come be a part of a filming in our SF store at Tout Sweet Patisserie this coming Monday at 10am, if interested, e mail info@toutsweetsf.com for more info.
hendersonrocks 5.0k
It's semi-nude Dale, promoting his new book!
(Click at your own risk.)
Curiosity got the better of me. Why did he think people would want to see him that way?
biakbiak 89.5k
Probably a drunken bet or dare. But whichever lots and lots of alcohol
But he's posting it so he must be proud. :)
Season 5 Champion Hosea Rosenberg hosted an interesting private event recently. Keep in mind that he's Colorado based. ;)
http://www.hightimes.com/read/top-chef-winners-pot-dinner
Lovecat 5.3k
Ack, you should have specified Dale TALDE...I thought it was going to be the *other* Dale! Hush, y'all, I think he's a cutie :)
Fabio's a daddy!!
https://www.facebook.com/ChefFabioViviani/photos/a.387022809931.162021.36219199931/10153661020844932/?type=3&theater
Awwww
http://www.sun-sentinel.com/business/consumer/fl-top-chef-cityplace-restaurant-20151006-story.html
A renowned South Florida chef and finalist on Bravo's "Top Chef" is partnering with a local restaurateur to debut a new restaurant early next year.
Lindsay Autry, a finalist on Top Chef's ninth season, is teaming up with Thierry Beaud, who owns bakeries and restaurants in Palm Beach County, to open the Regional Kitchen & Public House at CityPlace in West Palm Beach.
Kenny Gilbert appeared on Cutthroat Kitchen tonight. I recorded it but haven't watched yet, but I think he did well.
Lamb18 11.5k
Kenny won! He was by far the best one - he made the best dish in round 2, despite having two sabotages and the other chefs having none.
Sad news from Ron Eyester, participant in last season's competition.
http://atlantarestaurants.blog.ajc.com/2015/10/13/ron-eyester-confirms-rosebud-and-family-dog-are-closed-with-sales-pending-diner-will-stay-open/
This makes me want to visit the Dallas area!
http://dallas.culturemap.com/news/restaurants-bars/10-14-15-top-chef-tre-wilcox-cooking-class/
Chef Tre Wilcox, who became a local celebrity of sorts after his 2007 appearance on Top Chef, has a new venture called Tre Wilcox Cooking Concepts that is occupying an actual brick-and-mortar location at 8300 Preston Rd., right on the edge of Plano and Frisco.
It will serve as a unique hub for events, catering, team building competitions, and cooking classes, and will give guests the opportunity to work with Chef Tre in a hands-on environment while creating memorable culinary experiences.
After a 20-year career as a restaurant chef, private chef, and TV personality, Chef Tre is taking everything he's learned and applying it to a new setting where he can host individuals, couples, parties, and companies with his brand of fun, educational cooking classes.
Jeff and Janine opening another new restaurant together. I think he was on TC first, and then he and Janine hooked up after her stint on the show.
http://www.miaminewtimes.com/restaurants/jeff-mcinnis-and-janine-booth-return-to-miami-with-sarsaparilla-club-7993145
Top Chef's Tom Colicchio Gets Roasted by Celebrity Chefs in DC
http://www.washingtonian.com/blogs/bestbites/food-restaurant-news/chef-roast.php#.VjBD9oWxDN0.facebook
Looks like a fantastic time was had by all. Lots of photos at the linked site.
http://www.bravotv.com/the-daily-dish/harold-dieterle-top-chef-to-shutter-nyc-restaurants?cid=soc_dg_fb_TopChef
Top Chef Season 1 winner Harold Dieterle just announced that he will shutter his remaining two New York City eateries, Kin Shop and Perilla, by year's end. According to Eater, Kin Shop will close its doors by Thanksgiving, while Perilla is expected to close by early December. "The cost of doing business in New York is going up and up and up, and our sales haven't continued to go up to keep that in line. It's been very frustrating," he said about the decision. As for his impact in the culinary world, he had this to say, "I'm really proud of what we've done. It's all kind of run its course. It's gotten to the point where I'm not having fun and enjoying myself. I'm not saying I never want to return to the restaurant business, but right now, I'm feeling a little beat up and a little tired."
Bella 7.9k
That's sad. DH and I have visited Perilla 4 or 5 times and were hoping to return on our next visit to NYC. I hope we see him again in some capacity.
Rai 1.2k
Argh! I never got to go to Marrow, and I'd been dying to return to Kin Shop sooner than later.
Perilla was a special place for me and my ex, but I admit last time we went, there was a sense that the thrill was going from it. I chalked it up to Harold having moved on a bit and concentrating on his newer places, but maybe that malaise hit the other places too. Too bad, because I never had a bad time at any of them.
I sort of agree with this - no restaurant is perfect and they all have their misses. We experienced that at Perilla the last time we were there. Still, I believe in Harold's capacity to make great food and develop excellent restaurants, so I'm hoping he comes roaring back with something spectacular, even if he does shift gears for a while.
mlp 8.2k
Harold Dieterle has been showing up regularly as a judge on this season of Ilan Hall's Knife Fight. Maybe he thought the publicity would benefit his failing restaurants.
Wings 45.4k
Too bad about Harold, so many restaurants go this route. The chef/owner cannot keep up the grind. Getting TV gigs or a show is the ultimate goal for a chef. Harold doesn't have the personality to pull this off, unfortunately. I love the guy.
I wonder how all the restaurants owned by famous chefs keep going. We ate and one of Emeril's restaurants and it was mediocre at best. The vegetarian meal that was advertised on line did not exist. The two at our table who ordered it got a bunch of sides haphazardly thrown together and not good. Pucks restaurant on the same trip was excellent.
That's really too bad. I do think there are some Top Chefs who manage to keep high degree of quality. I can't speak highly enough of Bryan Voltaggio's Volt, for example. And Kevin Sbraga's restaurant in Philadelphia, Sbraga, is excellent as well. However, aside from appearing on TC Masters, Bryan V. hasn't been super-high-profile on the cooking shows, and I'm not sure that Kevin S. has appeared on national TV since winning his season of Top Chef.
PamelaMaeSnap 4.3k
Love the rabbit hole I just went down re-reading this whole thread (and Cooksdelight, you rock!) ...
THOUGHT I had posted about my experience (now experiences) at Kapnos, but since I haven't I'll throw in a comment here now, especially since I am officially getting SO EXCITED about the new season!
Have been to Kapnos three times now ... once seated in the main dining room for my birthday dinner and two more times when we ate at the bar (which was just as good except harder to enjoy the view of George in the kitchen). And seriously, this is BY FAR the best "Greek restaurant" in DC, as far as I'm concerned. We've yet to have anything that wasn't incredible, and the saganaki there is the best I've ever had anywhere (and I'm a saganaki fiend).
I live in the 'burbs and don't get into the city very often, but hubby directs a jazz vocal choir (among other things) that rehearses about 10 minutes from there on Tuesday nights and I'm in the group, so when we are not rushed for time (either by my work or his other work) we like to swing by there for dinner at the bar.
And there is no such thing as too much George ... I'm so excited that Kapnos Kouzina is opening in Bethesda eventually (it was supposed to be open already but has been experiencing construction delays and it's been pushed back to 2016 ... not surprising, watching the other restaurants at that interchange having been under construction seemingly forever) ... it's across the street from where I get my hair cut so I know who will be getting all of my lunch business on those days now!
ETA: I may have to check out Mexikosher this week ... my daughter lives less than a mile's walk from there so I want to swing by there and have a bite at Katsuji's place during one of my daily strolls. I loved Katsuji!
Edited November 22, 2015 by PamelaMaeSnap
Mexikosher is excellent, good food and good service. Ask for Katsuji, he's usually in the back and will happily come out and chat with you.
Qoass 6.8k
I'm listening to On Point on NPR and Stacey from Top Chef Boston is on to give Thanksgiving tips and explain how she got eliminated on the Thanksgiving episode.
Noreaster 896
From the S13:E02 episode thread:
Speaking of Jen, since I last checked on her last year, per looking at her Twitter now I mean, it seems like she's totally abandoned that lame duck idea of her own restaurant and is sucking at Mike Isabella's teat now. I can't tell if she works for him now or is a partner. Not sure it matters--either way it sounds nothing like the restaurant she talked about for years. EDIT - hah. That's because it's just a pop-up. I didn't get that until I checked more. Oh well. I suppose some day someone will think Jen's recovered enough of her sanity to run something permanent. We shall see...
The plan is for the Requin pop-up to open as a permanent restaurant in 2017. Of course, a lot could happen between now and then.
https://www.washingtonpost.com/news/going-out-guide/wp/2015/12/03/the-requin-pop-up-launches-next-week-in-the-mosaic-district/
On another note, Mike Isabella is opening restaurants at a ridiculously fast rate. In addition to multiple locations of Graffiato and Kapnos (the latter with partner George Pagonis of last season's Top Chef), he has partnered with other chefs in their ventures. An Asian noodle restaurant, a Mexican eatery, etc. Although it seems that in some of these restaurants, he may not be as involved in the food side of things but rather offering financial and business support. Here are a couple of links.
http://www.washingtoncitypaper.com/blogs/youngandhungry/2015/08/20/how-many-restaurants-does-mike-isabella-have-anyway/
https://www.washingtonpost.com/news/going-out-guide/wp/2015/11/19/jonah-kim-and-mike-isabella-set-to-open-yona-in-ballston-on-nov-30/
Jen's problem always seems to getting backers with deep pockets. She came close in Philly but something happened and it all went away. Whereas her counterparts from both of her seasons are all doing quite well.
Ariane Duarte (TC season 5) will be on Beat Bobby Flay tonight.
Julia 15.5k
Stephanie, bless her heart, is the guest chef on the holiday episode of Restaurant Impossible.
politichick 14.2k
I think that's accurate. He has three restaurants down the street from my office and while he definitely checks in, and sometimes lends a hand, he's not in the kitchen every night by any means. He's super nice, so it's always pleasant to run into him.
I watched Kevin Sbraga at Sbraga one night (I forget which season he won), and he was keeping 1 eye on the open kitchen and 1 eye on the guests. He entered the kitchen twice while we were there, once to talk to a couple of the cooks and once to do some hands-on cooking for about 5 or so minutes. It was as if he was making sure they met his standards. Like Spike, he has multiple restaurants and can't be in more than one place at a time.
Chrissytd 1.7k
Betty from Season 2 is on tonight's episode of Cutthroat Kitchen.
Edited December 28, 2015 by Chrissytd
I wondered if that was her. I could see why people didn't like her.
This year's James Beard semi-finalists are out, and there are a few Top Chef alums (and Isaac from the current season) on the list.
I hope all the chefs who shat on Bev during her season send her a bouquet.
Nah. That dreadful woman with the Chez Casa de la Maison House contental cuisine pub grub menu still maintains she was just standing tall for american food, and Sarah thinks it's enough not to be the dreadful woman with the Casa de la Maison House contental cuisine pub grub menu.
And speaking of people who deserve an apology, good for Isaac.
Edited February 17, 2016 by Julia
chiaros 948
Beverly Kim & Johnny Clark also won the Jean Banchet Awards "Rising Chef of the Year" prize.
http://chicago.eater.com/2016/1/19/10789602/2016-jean-banchet-awards-fat-rice-chris-pandel
Karen Akunowicz is also on the list (Best Chef: Northeast section).
Edited February 18, 2016 by chiaros
Jesse 2.9k
It was Karen who missed losing last year's award for the first episode of this season, wasn't it?

redpajama_set_name: RedPajamaCommonCrawl


Airolite Expandable cabin size trolley case has twin zips on main compartment, smart sleeve and a lockable RFID blocking pocket.
The security conscious traveller will appreciate the unique RFID blocking pocket helping to guard your identity from unlawful scanning devices. This expandable cabin size is ideal for the overnight trip.


Natures Script- Himalaya Herbal and Other Natural medicinal products.
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Opera by Request will be presenting a semi-staged version of a comic opera called "A chair in love" by Welsh-Canadian composer John Metcalf with libretto by Governor General award nominee Larry Tremblay. The plot revolves around an "urban angst" filmmaker who falls in love with a chair, and his faithful, if slightly jealous, dog who tries to save him from heartbreak.
The show will take place on Friday July 17th @ 7:30pm at the Array Space, and features William Shookhoff (music director and pianist), Abigail Freeman (Chair), Michael Robert-Broder (Truman), Gregory Finney (Dog), and Kim Sartor (Dogtor/Doctor).
Tickets for OBR's production are available online at Eventbrite tickets.


In a specific interview, the secretary general(SG) of al-Nujaba said: "We emphasize on the relation with the Seminaries and the religious Sources of Emulation, especially Qom and Najaf ones." He also applauded the attempts and endeavors made by Islamic Republic of Iran for prevention from the plots made by the enemies against Islam.
According to the secretary general of Al-Anwar Al-Najafia Foundation, the Foundation received the Geneva seat at the United Nations.


text:
Short Cuts: The Short Horror Roundup for September(ish)
Saturday, October 3, 2020 | Short Cuts
By BRYAN CHRISTOPHER
You may be wondering, dear reader, why this batch of short horror films for September has been released in October. It's best to think of it not that the September list is late, but that you're going to get not one, but TWO batches of horror shorts for October! Yeah, that's the ticket. Anyway, we've got some interesting stuff to get you in the Halloween mood, including an obnoxious YouTuber's public demise, some monkey's paw shenanigans, a peek at down the rabbit hole of extreme internet kink, and a unique look at how society might adapt to a catastrophic (and supernatural) event.
As always, if you or anyone you know have a short film you'd like me to consider or if you've got some news you'd like to share in the short horror world, please contact me via Twitter or email me at remedialhorror@gmail.com!
Chad Gets the Axe (2019)
Length: 13 minutes Director: Travis Bible Starring: Spencer H. Levin, Daniel L. Emmon
The best way to describe this movie is to imagine Jean Ralphio from Parks and Recreation doing a live feed from a murder house. Director Travis Bible and star Spencer H. Levin have to walk a fine line here, as the titular Chad needs to be annoying enough to enjoy what happens to him but not so annoying that we get turn off the movie halfway through. And they pull it off, even getting me to chuckle at some of Chad's antics even while I was acknowledging that he's a massive tool. Plus ,it doesn't hurt that in the end (spoiler alert) the title isn't a misdirect and we get the climax we're so badly hoping for.
Where you can find it: Streaming on Vimeo
We Got a Monkey's Paw (2018)
Length: 8 minutes Director: Aaron Pagniano Starring: Jacqueline Jandrell and Zack Ogle
Having a roommate can be a pain in the ass under the best of circumstances, but it's made so much worse when the person you share a place with has an affinity for cursed objects. In this case, a couple of roomies start messing with a monkey's paw only to find themselves trapped in a morass of the undead, time travel, self-murder, and more mishaps from the simian artifact. This one is horror by way of screwball comedy, and the central pair play damn well off one another.
Where you can find it: Streaming on YouTube
Black Pill (2019)
Length: 11 minutes Director: Jessi Gaston Starring: Avery Graham-Howard, Madeline Bernhard, Debo Balogun, Bella Wholey, Noah Berman, Gianna Mcgloon
Director Jessi Gaston explores a whole slew of heavy topics in this short about a transgender man deciding whether or not he's willing to let himself be literally destroyed for the sake of sexual gratification. Gaston dives into themes of identity, sexuality, our sense of worth, and the commodification of struggle. It's a messy film, both visually as we see the after-effects of the process, and figuratively as Gaston doesn't seem to offer clear answers as to how we're supposed to feel about the situation. But that's kind of the point as these topics don't lend themselves to simple answers.
Where you can find it: Making the festival rounds. Check out the trailer here
It's Normal (2018)
Length: 16 minutes Director: Nicole Solomon Starring: Latresa Baker, Tara Cioletti, Rory Lipede, Chas H. Cleveland, Karen Fleisch, Bradley True
It's pretty amazing (and sometimes scary) to consider how good we are as a species at normalizing pretty much anything. In the case of Nicole Solomon's It's Normal, a vampire uprising isn't so much marked by a dystopian wasteland as it is by support groups, crossbow sales, and potlucks meant to keep people in after sundown. Solomon makes a compelling statement about the callouses we build about the horrible things that happen in the world, either because we don't have a choice or because we're not emotionally capable of facing them. It's a film that scares us not just by showing us the way things could be, but by reminding us of the way they already are.
Aaron Pagniano
black pill
chad gets the axe
it's normal
jessi gaston
nicole solomon
travis bible
we got a monkey's paw
Bryan Christopher


text:
After Snafu, Mississippi Ratifies Amendment Abolishing Slavery
The actor Daniel Day-Lewis in the film Lincoln.
The movie Lincoln inspired a Mississippi citizen to push the state to correct a clerical error that kept the state from officially ratifying the 13th Amendment, which abolished slavery.
NPR's Debbie Elliott sent this report to our Newscast unit:
"In 1865, Mississippi was among the states that rejected the 13th amendment. But in 1995 lawmakers voted to change that. Problem was the state never sent official word to the U.S. archivist, so the ratification was never recorded.
"The paperwork snafu was discovered by Ken Sullivan after talking to a colleague at work about the movie Lincoln and the quest to abolish slavery. Sullivan contacted the Mississippi secretary of state, who agreed to send in the proper paperwork. Earlier this month the director of the federal register received the resolution, and declared that Mississippi had officially ratified the 13th Amendment to the U.S. Constitution."
The Jackson, Miss. Clarion Ledger spoke to Sullivan who said he was moved to tears by the film and that inspired him to act.
The paper adds:
"Why the copy was never sent in 1995 remains unknown.
"'What an amendment to have an error in filing,' said Dick Molpus, who served then as secretary of state. 'Thanks to Ken Sullivan for being a good citizen in bringing this oversight to light, so it can be corrected.'
"That Lincoln played a role pleases him, he said. 'It was one of the most inspirational movies I've ever seen.' "


To ask the Scottish Government what contingency plans are in place should it be decided that British Transport Police officers will not retain their dual status in Police Scotland.
As set out in the update recently provided to the Justice Committee, our planning assumption is that officers will transfer to Police Scotland with their existing status as both constables and employees. This position was reflected in a letter sent by the BTP Authority to all officers in Scotland.


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text:
Blog Home 10 reasons your muscles ache (and what to do about it)
10 reasons your muscles ache (and what to do about it)
Medically Approved
Some muscle pain is 100% expected — but some really isn't. Learn what could be making you feel sore and how you can get relief.
Kim Robinson
By Kim Robinson
It's probably no big surprise when your muscles feel stiff or sore the day after you deep-clean your house or give your treadmill a run for its money. Those are the kinds of aches we all might feel after we've moved our bodies a lot.
But other muscle pain is more mysterious. You might wonder why your muscles ache after a simple stroll around the block or why you still feel pain after a few days.
When your muscle pain doesn't go away or you're not sure of the cause, it's a good idea to talk to your doctor. "Everyone who has muscle pain deserves a full medical workup," says Nilanjana Bose, MD. She's a rheumatologist at the Rheumatology Center of Houston in Texas.
Here's a look at why muscle pain can happen — and what to do about it.
(Wondering what to do about high prescription medication costs? See how much you could save with our free mobile app.)
What exactly is muscle pain?
It's your body signaling to you that there's a problem. Depending on what's behind it, your muscles can feel sore, achy or crampy. Or the pain could be sudden or sharp. Some people feel muscle pain only in specific areas of their body, while others feel it all over.
The origin can vary, too. Muscle pain can come from within the muscle itself or from what surrounds it. That includes ligaments, tendons, bones and the soft tissue that connects the muscles, says Alka Gupta, MD. She's a clinical assistant professor of medicine at Weill Cornell Medicine and chief medical officer of Bluerock Care in Washington, D.C.
What causes muscle pain?
Muscle pain, also known as myalgia, can have many causes. Some are related to activity or tension. Others can result from illness, injury, infection or even the side effect of a medication.
The simpler and less serious causes of muscle pain usually clear up within a few days or weeks. And the pain is typically contained to a specific set of muscles.
Those causes can include:
Delayed-onset muscle soreness (DOMS). When you overexert a muscle, it can cause tiny rips or tears. To repair those tears (and come back stronger), your body sends more blood to the muscle.
"All of this causes swelling in the muscles, which causes the soreness," says Dr. Gupta. DOMS usually goes away after a few days and can be eased by taking over-the-counter pain medications such as acetaminophen or ibuprofen. Icing and light massage can help, too.
Stress and tension. Deadlines, traffic, figuring out what's for dinner. When we feel stressed, many of us tense up. Holding that position for a long time can lead to muscle pain, especially in the neck, shoulders and back. Taking time to relax, be it mindfulness exercises, a warm bath or a massage, can ease tension.
Dehydration. Not drinking enough water can cause muscle cramps, Dr. Gupta says. Fluids help your muscles contract and relax, according to the Mayo Clinic. If you notice your muscles seizing up, try increasing your water intake.
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When muscle pain stems from something more serious, other symptoms often come with it, says Dr. Gupta.
Other causes of muscle pain can include:
Nutrient deficiencies. Many vitamins and minerals play an important role in muscle function. If you're not getting enough of the key players such as magnesium or vitamin D, you could experience muscle cramps or pain, according to the National Institutes of Health. Another sign of low magnesium or D: excessive fatigue.
Fibromyalgia. It's a chronic illness that can prompt muscle and joint pain throughout the body, along with fatigue, sleep, memory and mood issues. The exact cause isn't known and there's no cure. But symptoms can be eased by managing stress, exercise and diet, according to the Cleveland Clinic.
Colds, flu and COVID-19. These illnesses can come with a side of muscle aches brought on by your body's immune response. With any of these infections, you could also have a fever, chills or congestion.
Lyme disease. This is an infection that comes from a tick bite. The overall inflammation from the infection can induce body aches and neck stiffness. (You might also have a fever, headache, fatigue or the telltale skin rash.) Here's how to reduce your risk of tick-borne illnesses.
Rheumatoid arthritis. It's a chronic inflammatory disease that attacks the joints and can sometimes bring on muscle spasms. Other common symptoms include stiffness, fatigue and painful swelling of the joints.
Taking statins. Several medications can cause muscle pain, such as those for treating cancer and high blood pressure. But statins, which treat cholesterol, are one of the more common medications linked with myalgia, says Dr. Bose. Some people even have to stop taking a statin because of it. We asked a pharmacist how to manage statin side effects.
Certain cancers. Sarcomas, which are soft-tissue cancers, can cause muscle pain if the tumor presses on nerves or muscles. Certain blood cancers such as leukemia can also result in muscle pain because the cancer reduces the amount of red blood cells the body makes. This means the muscles get less oxygen.
To figure out what's behind your muscle pain, your doctor will usually start with bloodwork, Dr. Bose says. They will also likely ask you questions, give you a physical exam and order labs and imaging tests, she adds.
Be aware that it can take time to find the source of your muscle pain, but it's important to stay on top of it.
"It's not always obvious what the cause is at the beginning," Dr. Gupta says. "So be patient with your doctor and follow up with him or her frequently to discuss your pain if it's persistent or gets worse."
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Additional sources
An overview of muscle cramp symptoms and causes: Mayo Clinic
Facts about magnesium: National Institutes of Health
Facts about vitamin D: National Institutes of Health
Treatments for fibromyalgia: Cleveland Clinic
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Search Results related to elements of art on Search Engine
Know The 7 Elements of Art and Why They Are Important
thoughtco.com
https://www.thoughtco.com/what-are-the-elements-of-art-182704
The elements of art are both fun and useful. Remember line, shape, form, space, texture, value and color. Knowing these elements will allow you to analyze, appreciate, write and chat about art, as well as being of help should you create art yourself.
Elements of art - Wikipedia
https://en.wikipedia.org/wiki/Elements_of_art
A work of art can be analyzed by considering a variety of aspects of it individually. These aspects are often called the elements of art.A commonly used list of the main elements includes form, shape, line, color, value, space, texture and perspective.
The Elements of Art - National Gallery of Art
nga.gov
https://www.nga.gov/education/teachers/lessons-activities/elements-of-art.html
The goal of this unit is to introduce students to the basic elements of art (color, line, shape, form, and texture) and to show students how artists use these elements in different ways in their work. In the unit, students will answer questions as they look carefully at paintings and sculpture to ...
Elements of Art - Getty
getty.edu
https://www.getty.edu/education/teachers/building_lessons/elements_art.pdf
Elements of Art The elements of art are the building blocks used by artists to create a work of art. Line is a mark with greater length than width. Lines can be horizontal, vertical, or diagonal; straight or curved; thick or thin. Shape is a closed line. Shapes can be geometric, like squares and circles; or
What Are the Seven Elements of Art? - Definition ...
study.com
https://study.com/academy/lesson/what-are-the-seven-elements-of-art-definition-examples.html
The elements of art are the building blocks of all art. Every piece of art ever created includes one or more of these elements. Learn about line, color, shape, form, value, space, and texture.
What Are the Seven Elements of Art and How Do They Work ...
mymodernmet.com
https://mymodernmet.com/elements-of-art-visual-culture/
The elements of art are concrete visual components that work in tandem with principals of art that organize and harmonize them. Line, color, shape, form, value, space, and texture are the seven core elements of art and they often overlap and inform one another.
What are the 7 Elements of Art? (Art Grammar, Part 1 of 3 ...
ridgelightranch.com
https://ridgelightranch.com/podcast-24-the-7-elements-art/
The 7 Elements of Art. The pictured 7 Elements of Art poster above is included in a few of my newer lesson plans, but is also available for purchase in my store for $3.99. Our email subscribers received a free copy of it recently, so if you like free stuff, be sure you're signed up for our email updates and that they aren't going to your ...
7 Elements of Art
https://www.youtube.com/watch?v=HZPIbqDFLI8
The Definition of Form in Art
https://www.thoughtco.com/definition-of-form-in-art-182437
The term form can mean several different things in art.Form is one of the seven elements of art and connotes a three-dimensional object in space. A formal analysis of a work of art describes how the elements and principles of artwork together independent of their meaning and the feelings or thoughts they may evoke in the viewer.Finally, form is also used to describe the physical nature of the ...


Art on Track is a yearly event where a six-car CTA train is converted into a mobile art gallery that circles the 'Loop' in Chicago. The cars are handed over for free to different local artists (or art groups) to curate.
It gives artists a unique location to display their art-ranging from paintings to performance art-and the public an opportunity to experience and interact with the art and artists in a setting that otherwise wouldn't be possible.
Art on Track was started in 2008 by group of students from the School of the Art Institute of Chicago. Since then it has become an important venue for emerging artists to exhibit alongside established artists.
While the train cars are given for free to the artists, there are many costs associated with putting on Art on Track. The organizer is currently running a Kickstarter campaign to cover the costs of renting the six-car train from the CTA, and publicizing the event and artists.
If you would like to fund Art on Track the lowest pledge level will get you a ticket to ride the Art on Track train this year. At the highest pledge level the Art on Track train will pick you and your friends up from any 'L' stop of your choice!


The 2005 Original Mac Games Cup has now officially opened for public voting. The submission phase has closed and there are 36 entries.
36 Free Original Mac Games to download and play. All we ask is that you take the time to vote and rate the games you play.
Update: It looks like iDevGames (host of OMG) is getting hammered with traffic. Please be patient, I'm sure they will be back up soon.


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2020 All-Michigan Team
Listed below is the 2020 All-Region Team for Michigan. This list was voted on by captains within the Michigan Region.
1. Ben Smart – Grand Valley State
Landing at #1 on the All-Michigan list in Grand Valley State star Ben Smart. Known for his great instincts, clutch catching, and devastatingly accurate throws, Ben Smart is the definition of an all-around player. At times this year it seemed like he could eliminate opponents at will. The lefty for the Lakers has such phenomenal movement and placement on his throw, and great timing in transition, that he can pick off opponents at a very efficient rate. Smart helped the Lakers to an undefeated record prior to the season being suspended, and while he would've loved to finish out the year with a National Title, he will be back next fall to help lead GVSU in their pursuit of a championship.
2. Dennis Sullivan – Michigan State
In his third year on the roster, Dennis Sullivan developed into a great leader and steady performer for the Spartans. One of Michigan State's most experienced athletes, Sullivan held a major role on the team, sparking their offense many times throughout the year. Sullivan is an all-around dodgeballer, with a great arm, and solid hands. His instincts, knowledge of the game, and leadership were keys to his team's success this year as the Spartans became a much more strategic and level-headed squad as the year went on. Sullivan and the Spartans were poised for a strong finish to the year prior to the Covid-19 outbreak, so we will have to wait until next season to see he and his teammates develop even more.
3. Nolan Stanko – Grand Valley State
Grand Valley State gets 2 of the top 3 in this year's All-Michigan list with Nolan Stanko landing at #3. Stanko has been a consistent producer for GVSU over the years, and in 2019-20 he stepped it up to another level. Time and time again, Stanko was a dominant force for GVSU this year. Stanko is an incredible transition player for GVSU, with good speed, a quick release, and of course, great reaction skills to dodge or catch. His presence was felt this year in a big way as he usually held down one side of the court for GVSU, usually playing from one sideline.
4. Jake Bruce – Saginaw Valley State
2019-20 was a bit of a rebuilding year for Saginaw Valley State University, as they were forced to give big minutes to many rookie players. For that reason, the team did not have a banner year, but they were still a strong, competitive team. The fact that SVSU was still relevant and able to compete with top-level teams is thanks in large part to the amazing talent and leadership of their veteran Jake Bruce. Bruce is a highlight machine, with quick feet, top-notch catching instincts, and a more than reliable throw. This year was an impressive one for Bruce, as he managed to help develop the SVSU roster over the course of the year, while also remaining a major standout performer. One of the best players in Michigan, and Nationally, Jake Bruce had a strong season in 2019-20.
T-5. Kyle Garner – Central Michigan
Central Michigan's Kyle Garner had quite the breakout season in 2019-20. A true play-maker for the Chippewas, when Garner was on his game, the Chips were a difficult team to beat. The CMU star stepped up into a bigger offensive role in 2019-20 and did not disappoint. He was a focal point of CMU's attack and had improved accuracy and timing on his throws all season. Garner makes a huge impact with his catching as well, often scooping up catches on balls that look near impossible to bring in. Garner is more than deserving of a spot on the All-Michigan list after the season he had in 2019-20.
T-5. Alex Jonauskas – Grand Valley State
Alex Jonauskas once again finds himself on the All-Michigan team after another strong year. A veteran leader for GVSU, Jonauskas was a big reason why GVSU had such a strong season, going undefeated prior to the season being suspended. Jonauskas is known for his amazing survivability at the end of points, and that was on display again in 2019-20. He is also a smart player who puts himself in the right position time and time again to secure transition kills, or make big catches. GVSU will have a hard time replacing this star next season. Congrats to Alex on making the All-Michigan list.
7. Jawanza Edwards – Central Michigan
Jawanza Edwards comes in at #7 on the All-Michigan list after a strong season. This second-year player really improved his game going into year 2. In 2019-20, Jawanza was a very dangerous catcher, and a dependable arm offensively as well. CMU was still a young team this year, but Jawanza and many other second year players on their roster stepped up as leaders and it showed. Edwards looked like a veteran on the court in 2019-20.
8. Jared Brown – Central Michigan
Jared Brown was the definition of a catalyst for Central Michigan this year. Brown embraced a much larger role this season, and was a major reason for the team's success. Brown did a fantastic job dictating the pace of the game, pushing his team up and down the court. When Brown was making plays, his team was thriving. Playing mostly from the middle of the court, Brown had much improved court awareness, strategy, and decision making this year. He and the Chippewas were poised for a strong finish to the season until it was suspended due to Covid-19.
9. Eric Nelson – Central Michigan
Eric Nelson makes the All-Michigan list after a solid 2019-20 season. Nelson was a great leader for CMU this year, helping them transition from losing two of their top arms a year ago and still remaining a force nationally. Nelson has a great side-arm throw and a good eye for making catches. He also is particularly dangerous at the end of points, always seeming to find the right timing to make a big throw. His skillset, and vocal leadership were both crucial pieces for Central Michigan in 2019-20.
10. Jacob Georges – Michigan State
Michigan State gets another player on the All-Michigan list thanks to Jacob Georges. The second-year player for MSU really developed in 2019-20, and was often the best player on the court. One of the most talented players in the state, Georges has a cannon of an arm, and is not afraid to get his body in front of a throw to make a catch. There were moments this year, even against the top teams in the country, where Georges would take over a point, making big throw after big throw. Considering the rapid pace at which he was improving his game, one has to think if the season weren't cancelled, Georges may have played his way higher on this list with a strong performance at Nationals.
11. Jack Hilt – Michigan State
Jack Hilt lands at #11 on the All-Michigan list after a solid 2019-20 season. While he battled through some injuries this year, Hilt was still able to be a standout performer for an improved Michigan State squad. Hilt is a big play waiting to happen, thanks to his strong arm, and unbelievable catch radius. Hilt is likely most well known for being able to make all-hands catches on throws whether they are an inch away from the ground, or far above his head. Having a playmaker like Hilt is always helpful, and MSU's solid season is due in part to Hilt's performance.
12. Josh Hill – Grand Valley State
Grand Valley State Captain Josh Hill makes his first All-Michigan list after leading the Lakers to an undefeated record in 2019-20. Hill came back from shoulder surgery to play this season, and while he was still rounding into shape in 2019-20, he was able to make a big impact for GVSU. Hill's leadership was crucial for the Lakers as they were able to remain undefeated all season, with a few clutch overtime wins along the way. Hill is a quick player in transition, and an opportunistic catcher. His all-around game improved throughout the year, and will be even more dangerous come next season once his shoulder is fully recovered and healthy.
Author: Kevin Bailey
Current NCDA Chief of Content. Former Captain for Grand Valley State University (#4).	View all posts by Kevin Bailey
Author Kevin BaileyPosted on June 18, 2020 June 18, 2020 Categories The Feed
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The Wisconsin Supreme Court will rule Friday on whether Marquette University went too far when it suspended a controversial professor for a blog post he wrote attacking a graduate student and philosophy instructor.
John McAdams, a longtime professor of political science and conservative commentator, sued Marquette after it suspended him in 2014 for his blog post attacking Cheryl Abbate. Abbate told students in her philosophy class that because everybody agrees with gay rights, there was no reason to discuss it.
McAdams included a clickable link to her personal website, and Abbate began receiving negative, threatening emails. She has since left the university.
Marquette contends McAdams' conduct was unprofessional because it "painted a target" on the back of a graduate student.
The case pits traditional conservative allies against one another.
The Metropolitan Milwaukee Association of Commerce supports Marquette's position, arguing in a legal brief that "a private employer is and should remain free to discipline an employee."
The Wisconsin Institute for Law and Liberty, which is defending McAdams, contends that Marquette's actions violated his right to academic freedom as a professor.
After the case was argued in April, McAdams told reporters that if the court sides with him, he'll return to teaching at Marquette.


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High-Dose Prednisolone Therapy for Lennox–Gastaut Syndrome Caused by Fentanyl Intoxication-Induced Toxic Leukoencephalopathy
Prednisolone Therapy in LGS
Publication date (electronic) : 2021 August 27
Hui Jin Shin, MD , Ji-Hoon Na, MD, Hyunjoo Lee, MD, Young-Mock Lee, MD
Department of Pediatrics, Gangnam Severence Hospital, Yonsei University College of Medicine, Seoul, Korea
Corresponding author: Young-Mock Lee, MD Department of Pediatrics, Gangnam Severance Hospital, Yonsei University College of Medicine, 211 Eonju-ro, Gangnam-gu, Seoul 06273, Korea Tel: +82-2-2019-3354, Fax: +82-2-2019-4881 E-mail: YMLEEMD@yuhs.ac
Received 2021 July 3; Revised 2021 August 1; Accepted 2021 August 2.
Lennox-Gastaut syndrome (LGS) is a severe form of childhood-onset epilepsy characterized by intractable seizures and developmental delay. LGS has a diverse etiology, including genetic, traumatic, metabolic, structural, and autoimmune abnormalities. The optimal therapy for LGS has not been well established, and treatment options generally include anti-epileptic drug therapy; dietary therapy, such as a ketogenic diet; or surgical treatment, such as vagus nerve stimulation, corpus callosotomy, or resective surgery [1]. Steroids have also been shown to be effective in patients with refractory epilepsy, especially in those with features of epileptic encephalopathy, including LGS [2,3]. Herein, we report the case of a patient with LGS caused by toxic leukoencephalopathy due to fentanyl intoxication, whose seizure frequency and electroencephalogram (EEG) patterns improved after high-dose steroid treatment.
A 27-month-old boy was diagnosed with toxic leukoencephalopathy caused by oral ingestion of a fentanyl patch at approximately 10 months of age [4]. Fentanyl intoxication may not only lead to cerebral damage and edema, but also cause overall brain damage and neurological deficits in pediatric patients. Toxic leukoencephalopathy was confirmed on brain magnetic resonance imaging (Fig. 1). The patient's condition led to delayed development and intractable seizures. The patient's age at seizure onset was 11 months. His seizures consisted of his arms alternatively becoming rigid, followed by generalized tonic-clonic movements. The patient was treated with multiple anti-epileptic drugs, including valproic acid, levetiracetam, clobazam, and vigabatrin. Initially, there was an improvement in seizure frequency, but soon after, the seizure frequency increased and the EEG findings continued to deteriorate, leading to the diagnosis of LGS.
Magnetic resonance imaging (MRI) findings. MRI findings indicating bilateral cystic encephalomalacia in the two parasagittal cortical border zones and the two frontal lobes. (A, B, C) Axial T2-weighted images. (D, E, F) Axial diffusion-weighted images.
Eventually, we decided to proceed with high-dose steroid treatment to control the patient's seizures. Prior to the high-dose steroid treatment, the patient experienced traumatic head-drop seizures more than 30 times per day. His EEG results showed a slow and disorganized background rhythm with very frequent multifocal sharp wave discharges, nearly continuous generalized spike and slow-wave discharges (GSSWs), and generalized paroxysmal fast activity (GPFA).
Initially, the patient was prescribed oral prednisolone (40 mg/day, 2.7 mg/kg/day) for 7 days. He did not have any serious side effects after steroid treatment. Therefore, we increased the prednisolone dose to 60 mg/day. He was also prescribed a proton pump inhibitor for stress ulcer prophylaxis to prevent upper gastrointestinal bleeding, which could be caused by high-dose steroids. After 5 days of treatment with the increased dose of prednisolone (60 mg/day, 4 mg/kg/day), the patient became seizure-free. On day 7 of treatment with the increased dose of prednisone, the patient's EEG patterns showed a dramatic improvement. His EEG results showed that GSSWs were almost absent, and that the frequency of the brief GPFAs had significantly reduced to less than 5% (Fig. 2). Since then, the patient has been prescribed prednisolone (60 mg/day) every other day to reduce the risk of developing Cushing's syndrome, and he has been seizure-free for more than 3 months. The patient has also shown developmental progress since the initiation of prednisolone therapy. We plan to continue the treatment by maintaining high-dose prednisolone (60 mg/day) every other day for 3 months, and then gradually reducing it over the next 3 months.
Electroencephalogram (EEG) findings before and after high-dose steroid therapy. (A) A slow and disorganized background with nearly continuous generalized spike and slow-wave discharges and generalized paroxysmal fast activity (before high-dose prednisolone treatment). (B) A significantly improved EEG status after high-dose prednisolone treatment.
This case demonstrates that leukoencephalopathy due to fentanyl intoxication can progress to LGS, and that high-dose prednisolone therapy may be an effective treatment option for LGS patients with toxic leukoencephalopathy. Although Mitsufuji et al. [5] reported an association between LGS and leukoencephalopathy, the current study is the first to report a case in which LGS associated with toxic leukoencephalopathy was successfully treated. The mechanism by which leukoencephalopathy progresses to LGS remains unknown.
The mechanisms underlying the anti-epileptic effects of steroids also have yet to be elucidated. One hypothesis is that steroids alter neurochemical transmission as a result of alterations in serotonin turnover or gamma-aminobutyric acid uptake. These effects may be mediated through the glucocorticoid or mineralocorticoid receptors, or both [6]. Another hypothesis involves corticotropin-releasing hormone (CRH) and high-dose steroids. High-dose steroid therapy has been used in certain cases of intractable epilepsy, such as West syndrome. Steroid treatment could reduce the levels of CRH, a pro-epileptogenic neuropeptide. Another hypothesis is that glucocorticoids may interact with central nervous system steroid receptors, which act as transcriptional regulators that influence voltage-dependent calcium channels [7]. In a previous report on West syndrome, prednisolone was administered orally (10 mg four times a day) for 2 weeks, accompanied by incremental doses if spasms continued [8].
There are limited studies regarding the use of high-dose steroids in other cases of intractable epilepsy, such as LGS. Therefore, the application of high-dose steroid therapy to treat patients with LGS requires considerable attention, and its efficacy and safety should also be considered. The adverse events associated with prednisolone therapy include irritability, the development of Cushing's syndrome, electrolyte disturbances, hyperglycemia, glucose intolerance, osteoporosis, bacterial infections, hypertension, and usually reversible dilatation of the ventricular and extra-ventricular cerebrospinal fluid spaces [2]. For this reason, it is important to reduce the dosage of steroids during maintenance and gradually taper it to prevent side effects. The maintenance and tapering methods for high-dose steroids in patients with LGS have not yet been established. It is important to maintain the efficacy of high-dose steroids as much as possible, while minimizing the side effects. Hence, further studies are required to determine the appropriate treatment duration and dosage of high-dose prednisolone therapy.
In summary, we report that toxic leukoencephalopathy due to fentanyl intoxication can progress to LGS, and that high-dose steroid therapy can be effective in treating LGS in such a situation. This case is expected to be a good reference for pediatric neurologists who treat LGS.
The present study was approved by the Institutional Review Board of Yonsei University Health System (IRB, 3-2020-0358). The board waived the requirement for informed consent.
Conceptualization: HJS, JHN, and YML. Data curation: HJS, JHN, and YML. Methodology: HJS, JHN, and YML. Visualization: HJS, JHN, and YML. Writing-original draft: HJS. Writing-review & editing: HJS, JHN, HL, and YML.
1. Thirunavu V, Du R, Wu JY, Berg AT, Lam SK. The role of surgery in the management of Lennox-Gastaut syndrome: a systematic review and meta-analysis of the clinical evidence. Epilepsia 2021;62:888–907.
2. Bast T, Richter S, Ebinger F, Rating D, Wiemer-Kruel A, Schubert-Bast S. Efficacy and tolerability of methylprednisolone pulse therapy in childhood epilepsies other than infantile spasms. Neuropediatrics 2014;45:378–85.
3. Gupta R, Appleton R. Corticosteroids in the management of the paediatric epilepsies. Arch Dis Child 2005;90:379–84.
4. Lim H, Lee H, Lee YM. Toxic leukoencephalopathy by accidental oral ingestion of an infant's fentanyl patch. Ann Child Neurol 2021;29:93–4.
5. Mitsufuji N, Ikuta H, Yoshioka H, Sawada T. Lennox-Gastaut syndrome associated with leukoencephalopathy. Pediatr Neurol 1996;15:63–5.
6. Mehta V, Ferrie CD, Cross JH, Vadlamani G. Corticosteroids including ACTH for childhood epilepsy other than epileptic spasms. Cochrane Database Syst Rev 2015;2015:CD005222.
7. Jacobson L, Sapolsky R. The role of the hippocampus in feedback regulation of the hypothalamic-pituitary-adrenocortical axis. Endocr Rev 1991;12:118–34.
8. O'Callaghan FJ, Edwards SW, Alber FD, Hancock E, Johnson AL, Kennedy CR, et al. Safety and effectiveness of hormonal treatment versus hormonal treatment with vigabatrin for infantile spasms (ICISS): a randomised, multicentre, open-label trial. Lancet Neurol 2017;16:33–42.