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Adaptation as Risk ManagementAgency FilingEnvironmental JusticeFinancial DisclosureFinancial RegulationRegulatory ActivitiesRisk Management

Comments to the OCC on Principles for Climate-Related Financial Risk Management for Large Banks

These comments to the Office of the Comptroller of the Currency (OCC) support the OCC's draft principles on banks' management of climate-related financial risks, and offer recommendations for the OCC as it continues building on these principles with more detailed guidance. The comments recommend that the OCC consider: (1) providing…
Stephanie Jones
February 14, 2022
Blog/News ArticleEnvironmental JusticeRisk Management

OSHA Takes Important First Steps to Address Growing Risks of Heat to Workers

As climate change intensifies heat-related risks in the workplace, the Occupational Safety & Health Administration (OSHA) is developing regulations that would provide critical protections for workers from heat hazards in indoor and outdoor settings — a process that should incorporate consideration of climate impacts and the firsthand expertise of affected…
Stephanie Jones
February 7, 2022
Agency FilingEnvironmental JusticeRisk Management

Comments on Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings (EDF, Institute for Policy Integrity)

These comments support an advance notice of proposed rulemaking by the Department of Labor's Occupational Safety & Health Administration (OSHA) as an important step in OSHA’s efforts to develop strong heat stress protections for workers. The comments recommend that OSHA consider climate change amplification of occupational heat risks and the…
Stephanie Jones
January 26, 2022
Financial RegulationRegulatory ActivitiesReport

Public Comments Overwhelmingly Support the US Labor Department Proposed Rule Addressing the Inclusion of ESG Criteria and Proxy Voting in ERISA-Governed Retirement Plans

This analysis of public comments found overwhelming support for the Department of Labor's proposed rule Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights, with 97 percent of comments in favor. The proposed rule affirms the ability of retirement plan fiduciaries to consider climate risk and other environmental,…
Stephanie Jones
January 25, 2022
Agency FilingFinancial RegulationRegulatory Activities

Comments on Department of Labor Proposed Rule on Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights

These comments support a Department of Labor proposed rule that clarifies that retirement plan fiduciaries should consider climate risk and other ESG factors whenever relevant to financial risk-return analysis for investment and proxy voting decisions. The comments additionally offer suggestions on potential improvements to the proposal for the Department's consideration.
Stephanie Jones
December 13, 2021