News & Analysis as of

EPCRA Clean Air Act Enforcement Actions

Foley & Lardner LLP

Revival of the General Duty Clause

Foley & Lardner LLP on

In a somewhat surprising decision issued at the end of 2020, U.S. EPA ruled that Section 112(r)(1) of the Clean Air Act, better known as the “General Duty Clause,” requires facilities to implement the latest industry...more

Vedder Price

The Environmental Black Swan: What Manufacturers Don’t Know They Don’t Know

Vedder Price on

Regardless of what side of the political fence you reside on and regardless of whether under this current administration you believe environmental enforcement has taken a holiday, the fact remains that most manufacturers...more

Williams Mullen

Refrigeration Systems Targeted: Risk Management Plans and Release Reporting

Williams Mullen on

Companies operating ammonia refrigeration systems are easy targets for EPA under a number of environmental programs. Recent history suggests release reporting under Section 112(r) of the Clean Air Act (CAA) and under the...more

McGuireWoods LLP

Regulatory Enforcement for Food and Beverage Industry Heats Up

McGuireWoods LLP on

Mid-to-late June 2016, federal and state authorities brought a variety of enforcement actions against food and beverage companies under environmental, health, and safety statutes, suggesting increased governmental oversight...more

Williams Mullen

Environmental Notes - October 2015

Williams Mullen on

In a significant setback for the Obama Administration, the U.S. Court of Appeals for the Sixth Circuit has temporarily blocked implementation of the Clean Water Rule issued jointly by EPA and the U.S. Army Corps of Engineers...more

Williams Mullen

EPA Puts Refrigeration Firm on Ice

Williams Mullen on

Millard Refrigerated Services Inc. learned the hard way that a company's failure to correct deficiencies in its processes can lead to significant consequences. Following three releases to the atmosphere from 2007 to 2010,...more

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