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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…
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…
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…
Adaptation as Risk ManagementAgency FilingRisk Management

Comments to Federal Acquisition Regulatory Council on Minimizing the Risk of Climate Change in Federal Acquisitions

In the normal course of operation for federal procurement under the Federal Acquisition Regulation (FAR), care is taken to structure purchases and contracts consistent with principles of efficiency, risk management, and cost minimization. Existing procedures, however, do not yet incorporate and manage financial risks posed by the consequences of climate…
Agency FilingEnvironmental JusticeRisk Management

Comments on Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings (Sabin Center)

These comments support an advance notice of proposed rulemaking by the Department of Labor's Occupational Safety & Health Administration (OSHA) on heat injury and illness prevention in outdoor and indoor work settings. The comments emphasize the importance of this initiative in combatting extreme heat, the most lethal climate disaster of…
Jacob Elkin
December 14, 2021
Adaptation as Risk ManagementBlog/News ArticleEnvironmental JusticeFinancial DisclosureFinancial RegulationPrivate GovernanceRisk Management

Climate Change Comes to Insurance

This opinion piece explains the risks climate change poses to insurers, both as underwriters and as investors. It argues that it is necessary to align incentives in the insurance industry to prevent widespread defaults that would leave policyholders unprotected and examine areas where risks are distributed inequitably.
Adaptation as Risk ManagementAgency FilingRisk Management

Comments on Federal Agency Climate Adaptation and Resilience Plans

These comments support the development of the Federal Agency Climate Adaptation and Resilience Plans, which establish a foundation for actions to protect government operations and facilities, and all who rely upon them. The comments recommend that agencies consider the following steps as they build on that foundation: (1) Agencies should…