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Are You Ready to Report an Accidental Chemical Release to Another Agency?

If your facility has a significant accidental release of a hazardous chemical, your team will need to respond immediately, particularly if the release threatens the public, workers, or the environment. But don’t forget to...more

EPA Region 1 Increasingly Targeting Ammonia Refrigeration Processes for RMP and General Duty Clause Enforcement

Over the course of 2017, U.S. EPA Region 1 has settled several significant enforcement matters arising under the risk management provisions of the Clean Air Act, Section 112(r). The risk management requirements are intended...more

EPA Delays Effective Date of RMP Rule Amendments, Environmental Groups File Challenge

On June 14, 2017, EPA published a final rule in the Federal Register delaying the effective date of its Risk Management Program (RMP) rule amendment package for twenty months, until February 19, 2019. EPA’s decision was...more

RMP and General Duty Clause Enforcement Continues at EPA Region 1

As we reported last year, the U.S. EPA has stepped up its enforcement activity under the risk management provisions of the Clean Air Act (“CAA”), Section 112(r), focusing on both the Risk Management Plan (“RMP”) program rules...more

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