Environmental Compliance: Lessons Learned the Hard Way. Craig J. Pritzlaff. A little about myself…. B.S. Bioenvironmental Sciences, Texas A&M University Worked with local, state, and federal environmental authorities J.D. Southern Methodist University
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Craig J. Pritzlaff
Numerous laws and increased enforcement:
LESSONS LEARNED: Plan Ahead
1. Know what the RQs are for toxic substances that could be released from your facility
2. Know how much volume or at what rate of release or emission it takes to exceed an RQ
3. Know who to call and how to answer the questions they are going to ask…
4. Finally, environmental staff should not be allowed to go on vacation.
FILING REPORTS - TRI
SOFTLY KILLING FIRE ANTS
Lessons Learned: FIFRA
Lessons Learned: FIFRA fire ants
EPA Penalty Policies: provide uniformity and discretion in amount of penalty assessed
Policies and most authorities give EPA discretion in negotiations to consider level of penalty, including degree of actual or threatened harm to environment or regulatory process; history of non-compliance; degree of culpability; attitude of company; other factors