EPA’s RMP Rule and the Broad Reach of the General Duty Clause (GDC)Many facility personnel assessed the applicability of EPA’s Risk Management Plan (RMP) rule when the program took effect in the 1990’s. This assessment likely involved reviewing the 140 listed...
An update to the International Organization for Standardization (ISO) 14001 standard was released in April 2026, introducing important changes designed to strengthen Environmental Management Systems (EMS) and improve organizational accountability. The transition...
As is currently written, the CWA Hazardous Substance FRP (HS FRP) requirements apply to the following facilities: Have a maximum onsite quantity of any CWA hazardous substance that meets or exceeds 1,000 times the Reportable Quantity (see 40 CFR 117.3); and Are within...
How Recent Storage Tank Failures Could Impact The Future of Environmental RegulationsRecent catastrophic events in the United States associated with storage tank failures at two facilities (Nippon Dynawave in Longview, WA; GKN Garden Grove, CA), have heightened...
Does your facility have cooling units or refrigeration equipment containing Hydrofluorocarbons (HFC)? Unless these units were relatively large (with a charge greater than 50 pounds), they were likely not regulated by the EPA. Until NOW………. The Environmental...
The United States Environmental Protection Agency (USEPA) has made two key announcements regarding the Clean Water Act (CWA) Hazardous Substance Facility Reporting Plan (FRP) Rule. They are both considering amendments to elements of the rule while proposing a deadline...
WHAT IS THE MULTI-SECTOR GENERAL PERMIT (MSGP)? USEPA has released a proposed draft of its updated Multi-Sector General Permit (MSGP). The MSGP offers NPDES permit coverage to 29 different industry sectors for discharging industrial stormwater from their facilities....