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Experience

Quarantine, Voluntary Disclosure and Corrective Action Plan

Upon discovery of potential TSCA violations, performed internal investigation and drafted voluntary self-disclosure to EPA on behalf of specialty chemical company.  Represented client in meeting with EPA enforcement office, emphasized favorable conditions and behavior, resulting in mutually agreeable Consent Agreement and Final Order with lowest penalty allowed by EPA Audit Policy.   Prepared Low Volume Exemption (LVE) application for subject substance in parallel with enforcement proceedings, resulting in sufficient authorized import volumes for client’s business needs.  Peripheral support activities included implementation of quarantine and monitoring of affected containers, collaboration with substance manufacturer/supplier, advising on Safety Data Sheet content and documenting waste/release procedures.

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