Representative Matters

  • Advising a major petrochemical company on the development of a company-wide spill release and reporting protocol under various release reporting statutes, including Section 304 of EPCRA.
  • Advising clients on the scope and application of the federal permitted release exemption under CERCLA Section 103 and EPCRA Section 304.
  • Advising clients in the chemicals, telecommunications, pharmaceuticals, and food processing sectors on the submission of voluntary disclosures to EPA that resulted in minimal penalties for past violations of EPCRA reporting requirements.
  • Defending a Fortune 100 client in a nation-wide enforcement action alleging several hundred violations of EPCRA Section 311-312 chemical inventory reporting requirements.
  • Advising a major US chemical company on integration and compliance issues concerning  EPCRA reporting in connection with a major asset acquisition of multiple facilities in multiple states.
  • Advising numerous clients over many years on the submission of annual Form R reports under the TRI program.