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SMG POV
by Ken Kirk (kenk@smithmanage.com)
On October 29, 2013, U.S. District Judge Reggie B. Walton ordered the Environmental Protection Agency to come up with a schedule to finalize its delayed rules on the handling and disposal of coal ash from power plants within 60 days. EPA promised federal regulations on the handling and disposal of coal ash several years ago after the December 2008 collapse of a coal-ash impoundment in Tennessee. A copy of the order can be found here.
FEATURED PROJECT
PROBLEM
A local company engaged in manufacturing imported a small amount of a chemical substance defined under TSCA. Faced with a potential EPA enforcement action with penalties assessed for noncompliance under TSCA of up to $32,500 per day per violation, the company called SMG for help.
SMG'S APPROACH
SMG analyzed the company’s current TSCA procedures and assisted the company in developing a proactive, cost-effective compliance procedure. SMG also facilitated a training program to educate employees about TSCA.
MG worked with the company to develop mechanisms that assured adherence with the policies that were being implemented for compliance. Procedures to promptly correct any potential violations and prevent future violations were also put into place.
RESULTS
SMG was able to show that the company complied with the relevant TSCA regulations and was improving their TSCA policies and procedures to assure that future issues were less likely to occur. The company was not subjected to the proposed penalties and now has mechanisms in place to maintain TSCA compliance.