For industrial, utility, and other clients subject to environmental reporting and record-keeping requirements to state agencies and/or to EPA (whether by statute, rule, permit, or other agreement) that might be impacted by employee absences or other interruptions associated with the COVID-19 pandemic: To date, we are unaware of any uniform response on how EPA or state environmental agencies will view specific reporting and record-keeping deficiencies during this period. Many state and EPA officials have been understanding about such special circumstances, but there is no uniformity or safe haven advice available. States seem to be varying their approach and to date we are unaware of any written guidance or a uniform guidance statement from EPA on deficiencies related to the COVID-19 virus effect on personnel responsible for monitoring and record-keeping. Some environmental deadlines are mandatory,  and there is limited discretion under the federal and state rules themselves for missing certain deadlines. The best thing a company can do is try to work with the relevant state environmental agency and/or EPA to address these things in advance of any deadlines that you will not be in a position to satisfy. It may be difficult to reach agency staff, but efforts can and should be documented. Where it is not possible to discuss with the agencies, document the circumstances related to the deficiency you cannot satisfy and attempt to address it as soon as possible with the state and/or EPA.