Hazardous Chemicals and the General Duty Clause
The applicability of the U.S. Environmental Protection Agency’s (EPA) Risk Management Program (RMP) is reasonably clear, but facilities with chemicals in amounts less than the RMP thresholds are finding themselves in trouble with the EPA because they are overlooking EPA’s General Duty Clause (42 U.S. Code 7412(r)(1)). Several times over the last 6 months the […]