Robinson Cole LLP
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Christopher Y. Eddy focuses his practice in the areas of environmental law, environmental litigation, facility siting, retail energy supply and utility regulatory law. He is an associate in our firm’s Environmental, Energy + Telecommunications group.

Environmental Law

Chris has extensive experience counseling clients on a wide variety of environmental issues. Chris has guided clients through matters involving the Comprehensive Environmental Response, Compensation, and Liability Act, the Clean Air Act, and the Resource Conservation and Recovery Act. He has also helped clients evaluate, manage, and plan for environmental risks associated with contaminated properties and their potential liability under state and federal law.

Chris has also counseled clients related to toxic torts involving issues such as fugitive dust and groundwater contamination. He has helped guide clients through all aspects of toxic tort litigation including initial dispostive motions, discovery, challenges to expert witnesses, motions in limine, and trial.

Land Use

Chris represents clients before the Connecticut Siting Council and other state and local land use boards related to renewable energy facilities, telecommunications facilities, and local zoning matters.

Retail Energy Supply

Chris also has experience counseling retail energy suppliers before the Connecticut Public Utilities Regulatory Authority (PURA) on issues such as regular reporting requirements, comments on PURA proposed decisions, the Renewable Portfolio Standard, and responding to PURA-issued interrogatories.

  • University of North Carolina School of Law (Juris Doctor, Moot Court)
    • Law Review
  • Bates College (Bachelors)
    • B.A., Psychology
    • History Minor

  • State of Connecticut

Publications


May 27, 2021

COVID-19 and its Impact on the OSHA Inspection Process

ISHN (Industrial Safety & Hygiene News)

Taking into consideration how COVID-19 has brought significant changes to OSHA’s inspection and enforcement focus, the article offers best practices for managing facility inspections, both generally and with specific references to COVID considerations. Read the article.

April 19, 2021

Combustible Dust and OSHA Inspections

EHS Today

The article focuses on OSHA’s Combustible Dust National Emphasis Program, which continues to be an area of focus and enforcement. While OSHA does not have its own combustible dust standard, the Administration has said it will rely on the General Duty Clause and National Fire Protection Association (NFPA) standards for enforcement. Guidelines to prepare for and handle OSHA inspections are in some cases universal, but when combustible dust may be a factor, there are some unique considerations for employers to be mindful of. Megan, Chris, Peter and Jon cover the actions employers can take before, during, and after an inspection to mitigate the potential for a citation. Read the full article.

March 2021

Avoiding Dust- Ups with OSHA over NFPA 652 Compliance

ISHN (Industrial Safety & Hygiene News)

The article offers an update on OSHA's Combustible Dust National Emphasis Program, which was launched in 2008 and continues to be an area of focus and enforcement. "While no OSHA standard directly addresses combustible dust, this has not hindered OSHA enforcement. Instead, OSHA has relied on the General Duty Clause and reference to the National Fire Protection Association (NFPA) standards when citing employers for combustible dust hazards." Under NFPA 652 facilities were required to complete an initial dust hazard analysis by September 7, 2020. Megan, Chris, Peter and Jon also briefly cover the applicable NFPA standards and OSHA’s compliance guidance. Read the full article.

May 27, 2021

COVID-19 and its Impact on the OSHA Inspection Process

ISHN (Industrial Safety & Hygiene News)

Taking into consideration how COVID-19 has brought significant changes to OSHA’s inspection and enforcement focus, the article offers best practices for managing facility inspections, both generally and with specific references to COVID considerations. Read the article.

April 19, 2021

Combustible Dust and OSHA Inspections

EHS Today

The article focuses on OSHA’s Combustible Dust National Emphasis Program, which continues to be an area of focus and enforcement. While OSHA does not have its own combustible dust standard, the Administration has said it will rely on the General Duty Clause and National Fire Protection Association (NFPA) standards for enforcement. Guidelines to prepare for and handle OSHA inspections are in some cases universal, but when combustible dust may be a factor, there are some unique considerations for employers to be mindful of. Megan, Chris, Peter and Jon cover the actions employers can take before, during, and after an inspection to mitigate the potential for a citation. Read the full article.

March 2021

Avoiding Dust- Ups with OSHA over NFPA 652 Compliance

ISHN (Industrial Safety & Hygiene News)

The article offers an update on OSHA's Combustible Dust National Emphasis Program, which was launched in 2008 and continues to be an area of focus and enforcement. "While no OSHA standard directly addresses combustible dust, this has not hindered OSHA enforcement. Instead, OSHA has relied on the General Duty Clause and reference to the National Fire Protection Association (NFPA) standards when citing employers for combustible dust hazards." Under NFPA 652 facilities were required to complete an initial dust hazard analysis by September 7, 2020. Megan, Chris, Peter and Jon also briefly cover the applicable NFPA standards and OSHA’s compliance guidance. Read the full article.

February 10, 2021

Breaking the chain of “substantial continuity” — Tenth Circuit clarifies test for repeat OSHA violations

ISHN (Industrial Safety & Hygiene News)

The Tenth Circuit Court of Appeals in Sec’y of Labor v. Wynnewood Refining Co. recently evaluated the applicability of the substantial continuity test in connection with an OSHA citation that included several repeat violations. The article offers background on the important role that repeat violations play in OSHA citations, how the substantial continuity test has been applied in determining whether a current company should be held liable for repeat citations based on citations from a prior company, and how the Tenth Circuit addressed that question in Wynnewood Refining. Read the full article.

January 7, 2021

COVID-19 and OSHA: Where we started and where we are now

ISHN (Industrial Safety & Hygiene News)

The article gives a brief summary of OSHA’s response to COVID-19 to date and where enforcement measures currently stand. The piece also examines COVID-19 enforcement trends and offers some insight on changes and challenges for employers in 2021. Read the full article.



February 10, 2021

Breaking the chain of “substantial continuity” — Tenth Circuit clarifies test for repeat OSHA violations

ISHN (Industrial Safety & Hygiene News)

The Tenth Circuit Court of Appeals in Sec’y of Labor v. Wynnewood Refining Co. recently evaluated the applicability of the substantial continuity test in connection with an OSHA citation that included several repeat violations. The article offers background on the important role that repeat violations play in OSHA citations, how the substantial continuity test has been applied in determining whether a current company should be held liable for repeat citations based on citations from a prior company, and how the Tenth Circuit addressed that question in Wynnewood Refining. Read the full article.

January 7, 2021

COVID-19 and OSHA: Where we started and where we are now

ISHN (Industrial Safety & Hygiene News)

The article gives a brief summary of OSHA’s response to COVID-19 to date and where enforcement measures currently stand. The piece also examines COVID-19 enforcement trends and offers some insight on changes and challenges for employers in 2021. Read the full article.

News


May 28, 2021

Megan Baroni, Chris Eddy, Peter Knight and Jon Schaefer Author ISHN Article on OSHA Inspections During COVID-19

Environmental, Energy + Telecommunications Group lawyers Megan E. Baroni, Christopher Y. Eddy, Peter R. Knight and Jonathan H. Schaefer authored the article “COVID-19 and its Impact on the OSHA Inspection Process” published in ISHN (Industrial Safety & Hygiene News) on May 27, 2021. Taking into consideration how COVID-19 has brought significant changes to OSHA’s inspection and enforcement focus, the article offers best practices for managing facility inspections, both generally and with specific references to COVID considerations. Read the article.

ISHN
April 23, 2021

Megan Baroni, Chris Eddy, Peter Knight and Jon Schaefer Author EHS Today Article on Combustible Dust and OSHA Inspections

EHS Today
March 16, 2021

Megan Baroni, Chris Eddy, Peter Knight and Jon Schaefer Author ISHN Article on Combustible Dust

Industrial Safety & Hygiene News (ISHN)
May 28, 2021

Megan Baroni, Chris Eddy, Peter Knight and Jon Schaefer Author ISHN Article on OSHA Inspections During COVID-19

Environmental, Energy + Telecommunications Group lawyers Megan E. Baroni, Christopher Y. Eddy, Peter R. Knight and Jonathan H. Schaefer authored the article “COVID-19 and its Impact on the OSHA Inspection Process” published in ISHN (Industrial Safety & Hygiene News) on May 27, 2021. Taking into consideration how COVID-19 has brought significant changes to OSHA’s inspection and enforcement focus, the article offers best practices for managing facility inspections, both generally and with specific references to COVID considerations. Read the article.

ISHN
April 23, 2021

Megan Baroni, Chris Eddy, Peter Knight and Jon Schaefer Author EHS Today Article on Combustible Dust and OSHA Inspections

EHS Today
March 16, 2021

Megan Baroni, Chris Eddy, Peter Knight and Jon Schaefer Author ISHN Article on Combustible Dust

Industrial Safety & Hygiene News (ISHN)
February 16, 2021

Megan Baroni, Chris Eddy, Peter Knight and Jon Schaefer Author ISHN Article on Substantial Continuity Test

Industrial Safety & Hygiene News (ISHN)
January 11, 2021

Megan Baroni, Chris Eddy, Peter Knight and Jon Schaefer Author ISHN Article on OSHA’s COVID-19 Response

Industrial Safety & Hygiene News (ISHN)

February 16, 2021

Megan Baroni, Chris Eddy, Peter Knight and Jon Schaefer Author ISHN Article on Substantial Continuity Test

Industrial Safety & Hygiene News (ISHN)
January 11, 2021

Megan Baroni, Chris Eddy, Peter Knight and Jon Schaefer Author ISHN Article on OSHA’s COVID-19 Response

Industrial Safety & Hygiene News (ISHN)

Environmental Law +


Below is an excerpt of Environmental Law + blog posts authored by Chris.

“Once In, Always In” for Hazardous Air Pollutants: Back to the Grave

After a few decades of uncertainty and “it’s-alive-it’s-dead-it’s-alive” swings, EPA’s “once in, always in” (OI/AI) policy is once again dead. And this time, it seems very dead. On June 20, 2025, President Trump signed a Congressional Review Act (CRA) resolution that rejects a September 2024 rule adopted by the Biden EPA that had revived a... Continue Reading

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Connecticut’s Amended Environmental Justice Statute: Where Does It Stand?

Earlier this year, the Connecticut Department of Energy and Environmental Protection (DEEP) released a “Connecticut Environmental Justice Public Participation Guidance Document” (‘the Guidance”) concerning the 2023 amendments to Connecticut’s environmental justice (EJ) statute regarding permitting or other approvals for certain facilities. Although helpful in indicating DEEP’s interpretation of the amended statute (which is not a model of... Continue Reading

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EPA Audit Policy Update – Scrutiny of Voluntary Self-Disclosures Set to Increase

The EPA intends to increase its review of voluntary self-disclosures of violations submitted electronically under EPA’s Audit Policy. The EPA Office of Inspector General (OIG) recently issued a report detailing the results of an evaluation of EPA’s process for screening self-reported environmental violations made through its eDisclosure system. The OIG’s report concluded that EPA currently... Continue Reading

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MA SMART Program: New Guidelines for Agricultural Solar Tariff Generation Units

On May 15, 2022, the latest revision of the Massachusetts Department of Energy Resources (DOER)  Guideline Regarding the Definition of Agricultural Solar Tariff Generation Units (Guideline) for the Solar Massachusetts Renewable Target (SMART) Program took effect. The Guideline supplements the SMART Program regulations (225 CMR 20.000), provides guidance on how a Solar Tariff Generation Unit... Continue Reading

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SCOTUS Temporarily Resurrects Trump-ERA Clean Water Act Rule

On April 6, 2022, by a 5-4 vote in the case of Louisiana, et. al. v. American Rivers, et. al., the Supreme Court temporarily resurrected a Trump-era rule that sought to stop the practice of many states and tribes from withholding or unduly conditioning their certifications that are required under the Clean Water Act before... Continue Reading

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Court Denies Class Certification in Illinois Oil Spill Case

On October 5, 2021, the United States District Court for the Southern District of Illinois denied the plaintiffs’ Motion for Class Certification in Morr v. Plains All American Pipeline, LLC 2021 WL 4478660 (S.D. Illinois, September 30, 2021). Plaintiffs’ claims arose out of a 2015 spill of approximately 100 barrels of crude oil at a... Continue Reading

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Nantucket Group Challenges Vineyard Wind Project in Federal Court

On August 25, 2021, the Nantucket Residents Against Turbines (ACK RATs) filed a complaint challenging the recent Environmental Impact Statement (EIS) on the proposed Vineyard Wind project to build wind turbines off the southern coasts of Martha’s Vineyard and Nantucket. ACK RATs’ chief concern is the potential impact that the Vineyard Wind project will have... Continue Reading

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Breaking the chain of “substantial continuity” — Tenth Circuit clarifies test for repeat OSHA violations

Below in an excerpt from an article authored by Robinson+Cole Environmental, Energy + Telecommunications Group lawyers Megan E. Baroni, Christopher Y. Eddy, Peter R. Knight, and Jonathan H. Schaefer that was published in ISHN (Industrial Safety & Hygiene News). The Occupational Safety and Health Act provides for increased penalties for employers who fail to rectify conditions following an Occupational Safety... Continue Reading

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