The EPA Enforcement Discretion Memorandum, COVID-19 implications for EPA’s Enforcement and Compliance Assurance Program (“Policy”), intent was, in general, the EPA does not expect to seek penalties for:
- Violations of routine compliance monitoring
- Integrity testing
- Sampling and laboratory analysis
- Training and reporting, or
- Certification obligations in situations where the COVID-19
- pandemic caused noncompliance
The caveat is your company has to provide supporting documentation to
both the EPA upon request and proper notification to your specific state environmental agency (e.g. IDEM, IL EPA, OH EPA.)
The Policy applies retroactively beginning on March 13, 2020. While this
Policy is not a “free ticket to ride” memorandum, the EPA expects your company to minimize the effects and duration of noncompliance caused by COVID-19 and return to compliance as soon as possible and document your return to compliance activities.
PATRIOT ENGINEERING AND ENVIRONMENTAL, INC IS HERE TO HELP!
- assist you with notifying your state environmental agencies to document your compliance activities during the pandemic.
- assist with the hardcopy requirements of report submissions set-forth by your individual state.
- help navigate state and local environmental agencies requirements to report, contain and remediate any accidental spills or releases of oil/hazardous substances/chemicals/waste.
- provide a complete environmental compliance audit that provides a multi-media review of your operations while “returning-to-normal” and assist in improving environmental compliance programs
CONTACT DAVID SERVIES TODAY AT DSERVIES@PATRIOTENG.COM OR BY PHONE AT 317-558-5064 FOR ANY OF YOUR REGULATORY COMPLIANCE NEEDS