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Williams Mullen Manufacturing Edge: Environmental Enforcement in the Current Regulatory Climate [Video]

THE MATTERS DESCRIBED IN THIS VIDEO ARE ILLUSTRATIVE OF THE MATTERS HANDLED BY THE FIRM. MATTER RESULTS DEPEND UPON A VARIETY OF FACTORS UNIQUE TO EACH MATTER. NOT ALL MATTER RESULTS ARE PROVIDED. MATTER RESULTS DO NOT...more

Unpacking the TSCA Polymer Exemption

Manufacturers of chemical substances in the United States are well aware of the regulatory burdens placed on their industry by the Toxic Substances Control Act (TSCA). TSCA requirements can be cumbersome and difficult to...more

Beat the Clock: Timely Reporting of Releases of Hazardous Substances

The obligation of manufacturing facilities to report releases of hazardous substances to local, state, or federal authorities is a complex regulatory subject. Multiple variables may impact whether a facility with a release to...more

EPA Amends TSCA Definition of “Small Manufacturer”

EPA recently issued a final rule amending Toxic Substances Control Act (TSCA) regulations concerning “small manufacturers” of chemical substances. Companies that meet the regulatory definition of a “small manufacturer” of...more

Containment Area Releases and the Limits of CERCLA Release Reporting Obligations

Manufacturing facilities commonly store various chemical substances in aboveground storage tanks. Most facilities ensure chemical storage areas are equipped with proper secondary containment measures to prevent releases of...more

EPA Issues TSCA PMN Guidance: Pointers for Submitters

EPA recently published guidance for companies preparing to submit new chemical notifications pursuant to the Toxic Substance Control Act (TSCA). The guidance, entitled Points to Consider When Preparing TSCA New Chemical...more

Know Your Chemical’s Potential without TSCA Oversight: The Test Marketing Exemption Explained

Manufacturers, importers and processors of chemical substances in the United States, know full well the regulatory burdens placed on their industry by the Toxic Substances Control Act (TSCA). TSCA requirements can be...more

Five Questions Every Industrial Facility Should Answer Before Applying for a Pretreatment Permit

Dischargers of industrial wastewater face a complex and nuanced set of federal, state, and local regulations aimed at protecting the water bodies into which they discharge. Industries discharging to local Publicly Owned...more

Environmental Notes - May 2018

New Source Review (“NSR”) remains a focus of enforcement for EPA. Between last year and now, EPA finalized eight settlements with manufacturers and one with a utility, asserting NSR violations for allegedly not obtaining a...more

Environmental Notes - March 2018

Since 1995, EPA has followed a policy that any air emissions source that emits one or more hazardous air pollutants (“HAPs”) above major source emissions thresholds is always considered a major source of HAPs. This is so even...more

Upcoming EPCRA Tier II Reports Must Use New Hazard Classifications

Manufacturers and large scale users of hazardous chemicals know the significance of March 1st. The Emergency Planning and Community Right-To-Know Act (EPCRA) requires facilities where hazardous chemicals were present above...more

EPA Wastewater Settlement Highlights Industry Focused Enforcement Initiative

EPA and the Department of Justice recently settled a Clean Water Act enforcement action with EMD Millipore Corp. of Jaffrey, NH, by lodging a Consent Decree in the U.S. District Court for the District of New Hampshire. The...more

Congress Finds the Formula to Reform Chemical Regulation

The Toxic Substance Control Act (TSCA) is the primary federal law by which the manufacture, import and use of chemical substances are regulated in the United States. Since its inception in 1976, TSCA has not been updated...more

TSCA 101 for Importers: Good Faith is No Defense to Faulty Compliance Certification

The Toxic Substances Control Act (TSCA) regulates the manufacture, use, disposal, and import of chemical substances in the United States. By defining the term “manufacture” to include the term “import,” TSCA places the...more

Lesson Learned from EPA Enforcement of EPCRA Form R Requirements

EPCRA § 313 requires certain facilities manufacturing or “processing” more than 25,000 lbs. or otherwise using 10,000 lbs or more of a listed toxic chemical to file a Form R annually on or before July 1. In the last two...more

Environmental Notes - June 2015

In this Issue: - EPA Issues SIP Call to Eliminate SSM Defense - EPA and Corps Define “Waters of The United States” - Frequent Questions: EPCRA 313 - Generators Need to be Vigilant About TCLP Sampling...more

Environmental Notes - May 2015

In this Issue: - Virginia’s Draft State Water Resources Plan - Frequent Questions: Form R Part II - Manufacturers and Temporary Workers - Farms and the Water Resources Reform and Development Act...more

Change Management for the Industrial Wastewater Discharger

Facilities discharging industrial wastewater to Publicly Owned Treatment Works (POTWs) must be keenly sensitive to changes in the nature and volume of their discharge. Proper planning, notification and interaction with the...more

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