As reported recently by E&E News, EPA’s acting enforcement chief, Larry Starfield, has directed agents to ramp up inspections in communities that have long been afflicted by pollution and called on agents “to step in and take necessary action” in cases where state regulators are failing to act in a timely manner.
Larry Starfield’s internal memo supports the Biden administrations focus on environmental and racial justice policy and challenges the “cooperative federalism” that was championed by the Trump administration, by empowering EPA inspectors to engage with communities, and provide more open communication and access to inspection reports via their online platforms.
What does this mean to you?
- Review your environmental programs and identify potential weaknesses – what is your plan to address these areas? Having a draft plan to address an issue is better than having no plan!
- Gather documents for your various environmental programs in a central location and make sure they are up to date
- Schedule an internal review of compliance information and documentation – fix any issues you come across
- Identify and designate an appropriate person who will be the lead for each of your programs, and who will be responsible for responding to EPA requests for site visits, document requests etc.
- Develop a Standard Operating Procedure (SOP) or similar for agency inspections
- If you have SOPs for routine or complex compliance, investigation or remediation tasks, make sure staff know where they are and are following them
- Engage with your local community leaders, listen to their concerns
- Consider developing and implementing a community engagement plan if you have sensitive facility issues
TRC can help prepare for inspections, respond to information requests, resolve Notices of Violation (NOVs), develop better SOPs/plans to prevent NOVs in the future, develop and implement a community engagement plan and more.
Please contact me at cvsmith@trccompanies.com for more information on how we can help you.
Catriona Smith
Catriona (Cat) Smith has over 30 years of professional experience in the interpretation and application of regulations for industrial facilities relating to compliance, remediation and negotiations with regulatory agencies. Her clients include upstream and downstream oil and gas, chem-pharma, petrochem, manufacturing and federal, state, and local governments. Ms. Smith is a Vice President and Environmental Sector Market Director for TRC, with nationwide responsibilities to manage our clients’ PFAS challenges, support and grow our Oil and Gas clients and bring multi-disciplinary solutions to their complex projects. Contact Cat at CVSmith@trccompanies.com