The United States Environmental Protection Agency (“EPA”) and Smith & Wesson Corp. (“Smith & Wesson”) entered into an April 27th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of: . . . Section...more
On December 9, 2015, the U.S. Environmental Protection Agency (EPA) published a Federal Register Notice announcing the launch of the eDisclosure portal, a centralized web-based system for receiving and automatically...more
The U.S. Environmental Protection Agency is modernizing its self-disclosure policy, commonly known as the Audit Policy, through a centralized “eDisclosure Portal” to receive and automatically process self-disclosed civil...more
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
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
Under EPA’s Audit Policy and Small Business Compliance Policy, companies that discover, promptly disclose, and expeditiously correct environmental violations may be entitled to penalty mitigation and other incentives. EPA...more
On June 10 and 15, 2015, the U.S. Environmental Protection Agency (EPA) rolled out a new system for e-reporting violations being disclosed pursuant to EPA’s audit policy, eDisclosure, which is expected to go on-line as soon...more
On June 10, 2015, the U.S. Environmental Protection Agency hosted a webinar describing a plan to modernize the implementation of its April 11, 2000 Audit Policy. The plan – called eDisclosure – attempts to provide a...more