We advise clients on all aspects of the Emergency Planning and Community Right-To-Know Act of 1986 (EPCRA), including facility emergency planning requirements, release reporting requirements, chemical inventory reporting, and Toxic Release Inventory (TRI) reporting. Our work has included developing reporting and compliance protocols for companies, advising clients on the completion of Section 311 submissions, Tier II reports and Form R submissions, successfully defending significant enforcement actions brought by EPA, and assisting companies with voluntary disclosures of past reporting violations under the statute.
Our work for businesses and trade associations has included the full range of legal services. We advise clients on compliance with EPCRA requirements and have designed and led in-house training workshops. We prepare comments on proposed regulations, such as those that have increased TRI reporting burdens, and we have represented clients in federal court challenges to those rules. We assist our clients in investigating allegations of non-compliance and determining appropriate responses, including identifying necessary corrective steps, evaluating whether to disclose potential violations under EPA’s Audit Policy, and, where necessary, defending clients in enforcement actions and citizen suits.