While the EPA is presumptuous that there will be gaps in compliance programs, it asserts that it will impose an actual indication of “impracticability” to excuse or mitigate non-compliance with remedial activity requirements. To help manage enforcement liability, the US EPA issued “Interim Guidance on Site Field Work Decisions Due to Impacts of COVID-19. Numerous state counterparts have also issued new enforcement discretionary guidelines and are emphasizing existing penalty relief mechanisms.
In the near term, act on prioritizing the physical security of human health and environmental receptors (HH/E) and take the required steps to qualify for state and federal enforcement discretion guidelines. (Source: J.D. Supra LLC, 2020).
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