Navigating Voluntary Disclosures Under New EPA/OIG Guidance to Mitigate Violations and Penalties
Distinguishing EPCRA From Non-EPCRA Violations
Recording of a 90-minute CLE video webinar with Q&A
This CLE webinar will advise environmental counsel on current EPA policies regarding voluntary self-disclosures. The panel will discuss how the EPA will evaluate EPCRA violations versus non-EPCRA violations and screen non-EPCRA violation disclosures for significant concerns. The panel will address how to mitigate risks for companies seeking to utilize the audit policy and submit non-EPCRA violation voluntary self-disclosure.
- EPA OIG Report
- 2015 eDisclosure portal
- Audit policy
- Categories of violations
- Changes in enforcement
- OIG recommendations
- Best practices for utilizing the audit policy
The panel will discuss this and other key topics:
- Why did the OIG conduct a review of the EPA's Audit Policy?
- What are the significant recommendations from the OIG's report?
- What are the likely resulting effects of voluntarily disclosing a Category 2 violation?
- How best can companies making a Category 2 violation disclosure mitigate risks?
Andrew H. Emerson
Holland & Knight
Mr. Emerson's practice focuses on helping clients develop and implement best-in-class advocacy and compliance... | Read More
Mr. Emerson's practice focuses on helping clients develop and implement best-in-class advocacy and compliance programs to ensure that they are positioned to effectively influence government regulation and to respond to oversight and enforcement activity by federal and state agencies – particularly with respect to environmental, health, and safety issues in the transportation, manufacturing and housing sectors. When clients must ensure compliance with applicable regulations, either proactively or due to government enforcement, Mr. Emerson helps develop well-designed, appropriately resourced, and practically effective compliance programs that can withstand scrutiny by government authorities and adverse private parties.Close
Pamela S. Goodwin
Saul Ewing Arnstein & Lehr
Ms. Goodwin represents clients in the energy, oil and gas, solid waste, agriculture, and many other industries in... | Read More
Ms. Goodwin represents clients in the energy, oil and gas, solid waste, agriculture, and many other industries in matters involving environmental permitting, counseling, and litigation. Drawing on more than 30 years of experience, she assists with acquisition, development, and siting of pipeline landfills, power plants, solar, and wind projects. Ms. Goodwin’s understanding of the complexities of securing government approvals is informed by her own current and past connections to government. She is a member of the New Jersey Clean Water Council, which serves as an advisor to the New Jersey Department of Environmental Protection and was chair in 2012 and 2013 and vice chair from 2008-2011. Early in her career, Pamela also served as special counsel to the Advisory Committee for Public Participation in Hazardous Waste Management in Pennsylvania, sponsored by the Pennsylvania Department of Environmental Protection.Close