News & Analysis as of

Noncompliance Enforcement Actions Environmental Protection Agency (EPA)

Mitchell, Williams, Selig, Gates & Woodyard,...

U.S. Environmental Protection Agency Complaint/Notice of Opportunity for Hearing Addressing Kapolei, Hawaii Waste Recycling...

The United States Environmental Protection Agency (“EPA”) filed a Complaint and Notice of Opportunity for Hearing (“Complaint”) against Unitek Solvent Services, Inc. (“Unitek”) on August 6th alleging violations of the Hawaii...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Removal of Title V Emergency Affirmative Defense Provisions/State Operating Permit Programs: U.S. Environmental Protection Agency...

The United States Environmental Protection Agency (“EPA”) issued a final rule in the July 21st Federal Register that removes the emergency affirmative defense provisions found in the regulations for state and federal Title V...more

Baker Donelson

Environmental Prosecutions Increased in Pandemic Year

Baker Donelson on

It is worthwhile for plant managers and environmental managers to pay attention to the types of cases involving environmental violations which are selected by regulators and prosecutors for criminal enforcement. That is...more

Clark Hill PLC

EHS Compliance and COVID-19: What EHS Executives Can Do Now (and as soon as the Dust Settles) - Updated

Clark Hill PLC on

This newsletter was updated April 17, 2020 to include recent guidance from California concerning regulatory compliance requirements. In the original newsletter below, we discussed two tools that may help Environmental,...more

Snell & Wilmer

ADEQ Issues COVID-19 Memo of Compliance & Enforcement

Snell & Wilmer on

On March 31, 2020, the Arizona Department of Environmental Quality (ADEQ) issued a Memorandum of Compliance and Enforcement Implementation During COVID-19. This memo of compliance is consistent with the March 26, 2020 United...more

Clark Hill PLC

EHS Compliance and COVID-19: What EHS Executives Can Do Now (and as soon as the Dust Settles)

Clark Hill PLC on

This newsletter was updated April 13. In the original newsletter below, we discussed two tools that may help Environmental, Health, and Safety (EHS) management respond to non-compliance arising from COVID-19: Agency...more

Sheppard Mullin Richter & Hampton LLP

U.S. EPA’s Temporary COVID-19 Enforcement Discretion Policy

On Thursday, March 26, the United States Environmental Protection Agency (“EPA”) announced and issued a Memo establishing an agency-wide temporary enforcement policy suspending or staying a broad array of enforcement efforts...more

Snell & Wilmer

EPA Announces Enforcement Discretion Policy for Noncompliance Caused by COVID-19 Pandemic

Snell & Wilmer on

EPA announced on March 26, 2020 a temporary enforcement policy regarding EPA enforcement of environmental legal obligations. In general, EPA does not expect to seek penalties for violations of routine compliance monitoring,...more

Pillsbury Winthrop Shaw Pittman LLP

COVID-19 Pandemic Will Soon be Impacting Compliance with and Enforcement of Environmental Laws

EPA existing guidance provides some conceptual anchoring for informing evolving risk management considerations. - Regulated parties face disruption of their ability to comply with environmental, health & safety laws due...more

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