We have drafted plans and protocols and provided advice concerning:
- EHS codes of conduct
- EHS management system plans
- Corporate compliance audit programs (internal and external)
- Corporate assessment and remediation programs (e.g., closure, decommissioning, cleanup or sale)
- Regulatory inspection and search protocols
- EHS incident reporting and investigation protocols
- EPCRA compliance programs
- EHS cost and liability reporting systems
- Training programs
- Employee reporting mechanisms (e.g., hotlines)
- Carbon management programs
EHS Compliance and Audits
- Assisting with self-reporting under South Dakota’s Audit Immunity Law due to a failure by the client to obtain required air permits; as a consequence, the client was allowed to correct the deficiencies and no notices of violation were issued and no fines were levied.
- Assisting with self-reporting several matters under Texas’ Audit Immunity Law due to discharges of oil and other substances onto pavement and gravel, as well as the failure to permit several air contaminant sources; as a consequence, the client was allowed to clean up the discharges and obtain the required permits without any notices of violation being issued or fines being levied.
- Assisting with self-reporting under Indiana’s Audit Immunity Law due to failure to have a required stormwater permit, failure to have required air permits and failure to submit hazardous waste reports; as a consequence, the client was allowed to correct the deficiencies and no notices of violation were issued and no fines were levied.
- Assisting with self-reporting of hazardous waste violations under Texas’ Audit Immunity Law with no penalty imposed.
- Assisting with self-reporting violations for disposal of hazardous waste in a non-hazardous waste landfill to the Michigan DEQ with no penalty imposed.
- Negotiating a substantially reduced penalty ($20,000 for alleged economic benefit) by self-reporting a company’s failure to submit EPCRA Section 313 reports for two facilities, each with 20 chemicals subject to reporting.
- Assisting manufacturers in identifying and correcting past EPCRA Toxic Release Inventory noncompliance issues as well as securing penalty forgiveness through use of U.S. EPA’s and various states’ audit policy protections.
- Providing voluntary audit disclosure submittals to U.S. EPA and several state agencies for various clients for failure to have proper air permits and/or failure to make various NESHAP filings that have resulted in complete forgiveness of gravity-based penalties.