Regulatory Resources – Registration Now Available for February 28 Webinar on the Clean Air Act General Duty Clause
On Tuesday, February 28 at 2pm EST, NACD will host a free Webinar, The Clean Air Act Section 112(r) General Duty Clause – What You Need to Know. The “General Duty Clause” (GDC) under Section 112 (r)(1) expands the range of activities the U.S. Environmental Protection Agency (EPA) is authorized to undertake to assure chemical safety, often in ways not fully understood by regulated entities. Owners and operators of facilities producing, processing, handling, or storing extremely hazardous substances must, under CAA Section 112(r), identify hazards associated with potential releases, design and maintain a safe facility, and minimize the consequences of accidental chemical releases. While the list of regulated substances and their thresholds regulated under the Risk Management Program and OSHA Process Safety Management is specific and finite, the GDC is not limited to a finite list of chemicals or established thresholds. This important point is often overlooked, and can make determining whether the chemicals at your facility need additional regulatory attention a difficult and uncertain task. The consequences of missing something are severe as EPA has increasingly been imposing severe fines on companies it determines are in violation of the GDC. To ensure that you know what is expected under the GDC before EPA auditors knock on your door, sign up today for this important Webinar. During the session, Lynn L. Bergeson and Kathleen M. Roberts of Bergeson & Campbell, P.C. will review EPA’s expectations for facility owners and operators related to chemical hazards, impacts of possible releases, and accident prevention. The Webinar will include an overview of the scope of the GDC, EPA’s new guidance regarding on-site compliance inspections, and offer recommendations on what NACD members can do to assure compliance, avoid surprises, and avert potential problems. Space is limited, so reserve your Webinar seat now at https://www2.gotomeeting.com/register/608458282.