Willful Blindness or Deliberate Ignorance – Either One Can Get You in Trouble

Willful Blindness or Deliberate Ignorance – Either One Can Get You in Trouble It does not matter if you purposefully decided not to look at the results of an audit, you could still be found culpable.  Let us suppose you

Posted in Current Affairs

The Executive Order on WOTUS – A Follow-Up

The Executive Order on WOTUS – A Follow-Up On February 28, 2017, the White House issued the Executive Order (“EO”) entitled “Restoring the Rule of Law, Federalism, and Economic Growth by reviewing the “Waters of the United States” Rule.”  The

Posted in Current Affairs, Environment, Environmental, Environmental Crimes

The Executive Order on WOTUS

The Executive Order on WOTUS On February 28, 2017, the White House issued the Executive Order requiring a review of the “Waters of the United States” rule.  The policy reasons, as set out in the EO, were to “ensure that

Posted in Current Affairs, Environment, Environmental, Environmental Crimes

Using USEPA CID to Provide 24/7 Security for Pruitt is Misguided

Using USEPA CID to Provide 24/7 Security for Pruitt is Misguided The new USEPA Administrator, Scott Pruitt, is expected to request an around-the-clock security detail from the USEPA, according to an internal USEPA e-mail.  This security request is in addition

Posted in Current Affairs, Environment, Environmental

Proper Storm Water Sampling Techniques

Proper Storm Water Sampling Techniques Is your sample collection a function of going out on a rainy day and just collecting a sample from any storm water you find?  If it is, you are unnecessarily exposing yourself and your company

Posted in Current Affairs, Environment, Environmental, Environmental Crimes

Audits – To Do or Not to Do

Audits – To Do or Not to Do The New Year brings all sorts of new issues.  There will have a new administration and, more than likely, a new enforcement focus.  That does not mean that good practices should be

Posted in Current Affairs, Environment, Environmental, Environmental Crimes

Lies, Damn Lies and Statistics

Lies, Damn Lies and Statistics According to a report recently released by the United States Sentencing Commission, the most common federal offense committed by “organizational offenders” (i.e. corporations, partnerships, unions, trusts, pension funds, and non-profits) was environmental crime.  Not fraud,

Posted in Current Affairs, Environment, Environmental, Environmental Crimes

Parallel Proceedings?

On December 12, 2016, the Seventh Circuit ruled that a civil determination adverse to the federal government precluded a criminal indictment. The case is U.S. v. Egan Marine Corporation and Dennis Michael Egan.   On January 19, 2005, a barge being

Posted in Current Affairs, Environment, Environmental, Environmental Crimes

USEPA Increases Civil Penalties

USEPA Increases Civil Penalties On July 1, 2016, the USEPA published its interim final rule that adjusts the statutory civil monetary penalty amounts. See 81 Fed. Reg. 43091. The rule was developed after passage of the Federal Civil Penalties Inflation

Posted in Current Affairs, Environment, Environmental, Environmental Crimes

Louisiana Flooding

Louisiana Flooding First off, a prayer for all of the victims of the Louisiana flooding, take care. Now, the recovery begins.  OSHA has many resources on detailing how to stay safe in the subsequent flood cleanup.  See  https://www.osha.gov/dts/weather/flood/index.html The flood

Posted in Current Affairs, Environment, Environmental, Environmental Crimes

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