It has now been more than six months since Congress allowed the statutory authority for the Chemical Facility Anti-Terrorism Standards (CFATS) program (6 CFR Part 27) to expire on July 28, 2023. EPA recently advised all...more
Since the November presidential election, most trade journals have expressed the same or similar headlines: “The Joe Biden/Kamala Harris administration will elevate enforcement for violation of environmental rules and...more
Comprehensive Risk Management Plans (RMP) under Section 112(r) the Clean Air Act (Act) are not just required for facilities processing listed regulated substances in excess of regulatory thresholds. Recent EPA enforcement...more
Employers may be liable for failing to file incident reports and properly record employees affected by COVID-19 on OSHA 300 and 300A logs. If it can be shown the illness is contracted at work, OSHA may expect the illness to...more
EPA recently issued a final rule containing much-debated revisions to the Clean Air Act 112(r) Risk Management Program (“RMP”). The rule rescinds or modifies a substantial number of existing requirements, including...more
1/14/2020
/ Amended Regulation ,
Clean Air Act ,
Disclosure Requirements ,
Environmental Protection Agency (EPA) ,
Executive Orders ,
Final Rules ,
Incident Response Plans ,
Obama Administration ,
Regulatory History ,
Rescission ,
Risk Management ,
Rulemaking Process ,
Trump Administration
It’s well-known that the Trump administration has sought policies of deregulation over the past several years. The administration places emphasis on proper enforcement of existing rules and regulations as a means of achieving...more
1/13/2020
/ Administrative Procedure ,
Carbon Emissions ,
CERCLA ,
Clean Air Act ,
Climate Change ,
Department of Environmental Quality ,
Energy Policy ,
Energy Sector ,
Environmental Policies ,
Environmental Protection Agency (EPA) ,
Executive Orders ,
Gas Prices ,
Obama Administration ,
PFAS ,
Renewable Energy ,
Risk Management ,
Rulemaking Process ,
Transportation Industry ,
Trump Administration ,
US Army Corps of Engineers ,
Waste Treatment Facilities ,
Wastewater ,
Waters of the United States
A trilogy of recent federal and state enforcement actions show just how far agencies will go to enforce environmental regulations. Now may be a good time for a compliance audit....more
2/14/2018
/ Appeals ,
Batteries ,
Civil Monetary Penalty ,
Clean Air Act ,
Clean Air Act Violations ,
Compliance ,
Consent Agreements ,
Criminal Convictions ,
Criminal Prosecution ,
DirecTV ,
Discharge of Pollutants ,
Enforcement Actions ,
Environmental Crimes ,
Environmental Protection Agency (EPA) ,
Environmental Violations ,
Hazardous Substances ,
Hazardous Waste ,
Land-Use Permits ,
Landfills ,
Mining ,
Reaffirmation ,
Reporting Requirements ,
Retailers ,
Risk Management ,
State and Local Government ,
Suction Dredge Mining ,
Toxic Chemicals ,
Waters of the United States ,
Wetlands
Companies operating ammonia refrigeration systems are easy targets for EPA under a number of environmental programs. Recent history suggests release reporting under Section 112(r) of the Clean Air Act (CAA) and under the...more
7/10/2017
/ CERCLA ,
Clean Air Act ,
Corporate Financing ,
Emergency Response ,
Enforcement Actions ,
Environmental Protection Agency (EPA) ,
EPCRA ,
Food Manufacturers ,
Manufacturers ,
Reporting Requirements ,
Risk Management
As we reported in the April issue of Environmental Notes, the Trump administration issued a final rule on March 16, 2017 that delayed the effective date of regulations making significant changes to requirements applicable to...more
OSHA has come full circle…almost. In a December, 2015 revised interim enforcement memorandum, the agency indicated it will not enforce the Process Safety Management (PSM) Standard for “highly hazardous chemicals” (HHC)...more