News & Analysis as of

Environmental Protection Agency (EPA) Self-Reporting

Roetzel & Andress

Biden Administration Changes to Enforcement Policies

Roetzel & Andress on

This year, the Biden Administration has ushered in changes to enforcement guidance and policy, including criminal self-disclosures and deference to State regulators. In addition, the Administration has further bolstered its...more

Womble Bond Dickinson

EPA to Increase Review of Voluntary Self-Disclosures of Violations

Womble Bond Dickinson on

On June 30, 2022 the EPA Office of Inspector General (“OIG”) issued the results of an evaluation to determine if EPA’s process for screening self-reported environmental violations through electronic disclosure is effective....more

Beveridge & Diamond PC

EPA Increases Scrutiny of Self-Reporting Through the eDisclosure System

On June 30, 2022, the U.S. Environmental Protection Agency (EPA) Office of Inspector General (OIG) issued a report titled “Additional Internal Controls Would Improve the EPA’s System for Electronic Disclosure of Environmental...more

Womble Bond Dickinson

EPA Relaxes TSCA Reporting Requirements

Womble Bond Dickinson on

In a welcome course change, the EPA has announced three exemptions to a potentially costly reporting program for manufacturers. The Toxic Substances Control Act (TSCA) Title VI Fee Rule identifies 20 “high priority chemicals”...more

Bass, Berry & Sims PLC

Failure to Voluntarily Self-Report is a "Non-starter" under the FCA

Bass, Berry & Sims PLC on

On July 5, 2019, the D.C. Circuit Court of Appeals affirmed dismissal of a qui tam lawsuit against several chemical manufacturers that set forth a unusual theory of liability: the relator alleged that the manufacturers...more

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

EPA Enforcement of Toxic Release Inventory (TRI) Late Reporters: U.S. EPA Office of Inspector General Project Notification

The United States Environmental Protection Agency (“EPA”) Office of Inspector General (“OIG”) issued a Project Notification titled: EPA Enforcement of Toxic Release Inventory (TRI) Late Reporters - The Project...more

Ballard Spahr LLP

MDE Self-Disclosure Can Limit, Even Eliminate Risk of Environmental Penalties

Ballard Spahr LLP on

Maryland entities that voluntarily discover and disclose environmental violations can still receive penalty reductions, or even complete forgiveness, under the rarely invoked Maryland Department of the Environment (MDE)...more

Best Best & Krieger LLP

Best in Law: Get Out in Front on Possible Environmental Violations

It’s no secret that businesses must run a gauntlet of federal, state and local environmental regulations in order to successfully operate in California. But the hardest test may be when a business suspects that it may be...more

Williams Mullen

Williams Mullen Construction Industry Newsletter - Spring 2016

Williams Mullen on

2016 begins with the issuance of this Construction Industry Newsletter, our fifth. In this issue, we have articles on vapor intrusion, liability for project design, enforcement of mechanic’s lien and bond waiver clauses, and...more

Miles & Stockbridge P.C.

EPA Launches eDislcosure for Self-Reporting Violations

As expected and last reported in our June 2015 blog, the U.S. Environmental Protection Agency (EPA) on December 9, 2015, launched eDisclosure — EPA’s updated, electronic voluntary audit and disclosure reporting system. Under...more

Davis Wright Tremaine LLP

EPA’s Audit Policy eDisclosure: Electronic Self-Reporting for Environmental Violations

Reporting uner EPA’s audit policy, which has provided relief from gravity-based penalties to those who self-report, is about to become much easier. This fall, EPA expects to launch a centralized web-based “eDisclosure” portal...more

Davis Wright Tremaine LLP

Electronic Disclosure of Violations Coming This Fall

Under EPA’s Audit Policy, those who discover, promptly disclose and correct environmental violations may have penalties reduced or eliminated. 60 Fed Reg 66, 705 et seq. (1995); 65 Fed Reg 19, 617, et seq. (2000) EPA recently...more

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