With considerable fanfare, including news conferences in every EPA region, the Agency unveiled its Action Plan for per- and polyfluoroalkyl substances (PFAS), a large class of manufactured chemicals that have proven to be highly effective in many industrial applications and have also spread risks to human health through sources of drinking water across the nation. […]
The Tier II hazardous chemical inventory reporting deadline is quickly approaching. Are you prepared to submit your report by March 1st?
Although the EPA is at the moment essentially crippled in the midst of the ongoing government shutdown, we have a few enforcement items to report from late 2018. Our latest roundup of five cases includes RCRA, EPCRA, and TSCA violations.
A spill or release of a chemical just occurred at your facility. What do you do? Does it need to be reported? What information needs to be reported, to whom, and how soon?
The EPA’s enforcement of violations of environmental laws and regulations at federal facilities is a complicated business that has been addressed by the U.S. Supreme Court (Ohio v. United States Department of Energy, 1992, which affirmed federal facility sovereign immunity with respect to the Resource Conservation and Recovery Act (RCRA)), presidential Executive Orders, and by […]
The EPA is proposing to extend an existing reporting exemption under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) to release notification rules under the Emergency Planning and Community Right-to-Know Act (EPCRA). The CERCLA extension applies to air emissions from animal waste at farms.
While our September 2018 environmental enforcement roundup isn’t as dramatic as some of our other recent reports, it still provides valuable lessons for organizations that want to avoid becoming the next statistic. It’s also worth noting that a provider of environmental services (which you’d think would know compliance backwards and forwards) made this month’s list, […]
The EPA recently found a company in violation of the Emergency Planning and Community Right-to-Know Act’s (EPCRA) hazardous chemical inventory (also known as Tier II) and Toxics Release Inventory (TRI) reporting requirements and levied a penalty of over $160,000. Are you confident in your compliance with EPCRA reporting requirements? Now might be a good time […]
The EPA has issued a direct final rule—that is, an action for which there was no prior opportunity for public comment, and, in this case, one that is effective immediately—that appears to put an end to a 10-year dispute over whether air emissions from animal waste at farms should be subject to reporting under the […]
Our first environmental enforcement report for August 2018 has summaries of five recent cases—and two of them resulted in penalties of over $1,000,000. It’s an ongoing reminder of the importance of environmental compliance to an organization’s bottom line.