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Temporary COVID-19 Enforcement Policy Issued by EPA

OnDemand Webinar (76 minutes)

Understand the scope of the EPA's temporary enforcement policy and situations in which the policy will be implemented.The EPA acknowledges that the travel and social distancing restrictions imposed by governments, along with guidance from other agencies, may affect facility operations and the availability of key staff and contractors, or the abilities of a facility or lab to analyze and report on samples; which, in turn, could affect a facility's ability to comply with certain reporting obligations and milestones, or meet enforceable limitations. Accordingly, on March 26, 2020, EPA announced it is temporarily relaxing enforcement of certain environmental legal obligations where noncompliance is due to or caused by the COVID-19 pandemic. With this temporary enforcement policy comes many questions including how and when it will be applied, compliance, monitoring and reporting issues. The EPA has also issued specific guidance related to CERCLA/RCRA field work with COVID-19 restrictions in place, and the measures outlined in that guidance to address noncompliance also raise important issues for responsible parties to consider when operating in this public health emergency.


Frank J. Deveau, Taft Stettinius & Hollister LLP Kodi J. Verhalen, Taft Stettinius & Hollister LLP


Applicability of EPA's Temporary Enforcement Policy

• Time Frame - When Does the Policy Apply?

• EPA Resource Allocation - What Situations Take Priority?

General and Specific Policy Conditions

• General Conditions to Qualify Under the Policy

• Routine Compliance Monitoring and Reporting by Regulated Entities

• Training Requirements

• Signatures and Submissions

• Settlement Agreement and Consent Decree Reporting Obligations and Milestones

• Facility Operations That Pose an Acute Risk or Imminent Threat

• Hazardous Waste Generators

• Animal Feeding Operations

• Critical Infrastructure

Documentation Requirements

Important Carve-Outs

• CERCLA and RCRA Sites

• Imports or Restrictions on Items Claiming to Address COVID-19 Impacts

• Accidental Releases

• Criminal Violations/Conditions of Probation in Criminal Sentences

• Public Water Systems Expectations

Site Field Work Decisions/CERCLA and RCRA Cleanups

• EPA Priorities

• General Guidance for Field Work Decisions

• Factors Considered for Field Work Decisions

Frequently Asked Questions