The sharp increase in environmental regulations in recent years has led to rising compliance concerns among regulated entities. Environmental regulations have increased in number and in scope of coverage at all levels of government, most notably at the federal and state levels. This has made achieving and managing environmental compliance issues more difficult. Yet compliance must be taken very seriously; civil penalties for violations of environmental statues can be up to $50,000 per day. In an increasing number of cases, violators — even those who intended to do no harm — are receiving harsh jail sentences. Regulatory compliance reviews may need to be conducted when:

• Facility managers are not familiar with environmental regulations and issues that may exist. Regulators rarely allow management personnel to plead ignorance of environmental regulations.

• Issues exist that may require capital funding for future corrective measures.

• Capital improvement occurs, a process changes, or maintenance activities are undertaken in an operations facility, regulatory obligations may be triggered.

In some cases, our clients use compliance reviews when regulations are merely proposed to prioritize areas of potential impact and to accurately budget capital spending for the purpose of closing known potential issues.

Some regulatory obligations may be readily apparent; for example, obtaining an air permit for a new paint booth. However, others may be less obvious, such as updating a spill plan in conjunction with a parking lot expansion. Typical facility activities which can trigger environmental regulatory obligations include:

• facility expansion;

• equipment addition or removal;

• sanitation practices; and

• production changes.

The object of our Regulatory Compliance Review is to develop corporate policies where facility employees maintain day-to-day compliance with environmental regulations in a cost effective manner.

Many times, our clients request that we achieve "closure" of known issues, reduce waste streams, and assist with implementing new policies. We can also provide training to key personnel for employee accountability and to incorporate environmental considerations into business decisions.

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