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12 Jul 2018PHMSA Enforcement Actions – What’s Trending?
This post was co-authored by partner Paul Drucker, and Summer Associate, Zachary Miller. A review of the Pipeline & Hazardous Materials Safety Administration (PHMSA) enforcement statistics continues to emphasize enforcing “lesser” safety violations committed by hazardous liquid pipeline operators. This trend may be part of an enforcement strategy to prevent more sizable and dangerous violations
25 May 2018The Undead is Given New Life – Welcome Resurrection of EPA’s Audit and Self Disclosure Policies
On May 15, 2018, U.S. EPA announced its intent to renew its emphasis on encouraging the regulated community to voluntarily discover and promptly disclose and correct environmental violations. This was welcome news because this program – which had been very popular with regulated entities since the Agency first rolled out its Audit Policy in 1997