Susan Bodine

August 30, 2018

DOJ/EPA pursue criminal charges involving environment and worker safety . . .

The recent indictments out of Nebraska related to the deaths of two workers and mishandling of hazardous waste demonstrates EPA’s and DOJ’s continued focus on the intersection of environmental protection and worker safety.  With substantially larger criminal penalties for certain environmental violations than available in worker safety statutes, the DOJ, EPA and OSHA will look to apply […]
August 27, 2018

EPA Announces New National Compliance Initiative

EPA’s Enforcement Chief, Susan Bodine, issued new guidance this week, announcing movement away from “enforcement” to “compliance” initiatives.   The initiative underscores the approach the agency is taking to lighten its civil enforcement footprint, encourage states and tribes to take the lead where they can, and promote compliance over enforcement as a matter of policy.   National Enforcement […]
May 7, 2018

EPA announces new audit policy (and self-reporting) to addresss significant noncompliance in oil and gas industry . . .

New Owner Clean Air Act Audit Program for Oil and Natural Gas Exploration and Production Facilities Related Information Materials from February 2018 Oil and Natural Gas Roundtable to enhance coordination and communication, and ensure responsible domestic energy production Unconventional oil and gas New Owner Audit Program The EPA is in the process of developing a New […]
April 3, 2018

EPA Tries New Informal Enforcement Approach

*** EPA’s chief of enforcement, Susan Bodine, has set her sights on a new approach to improve compliance, “informal enforcement”, bringing to bear Scott Pruitt’s priorities of cooperative federalism and “back to basics”.   The approach is being criticized by some as more roll-backs, others are hailing the measure as a better way to improve compliance, […]
February 12, 2018

Trump EPA Touts Enforcement as Key to Positive Health and Environmental Outcomes

The release of EPA’s fiscal year 2017 enforcement results give a picture of the enforcement priorities .  The results reflect four months of the Obama administration and eight months of the Trump administration, and the major cases that make up the results in terms of pollution impacts, fines, and injunctive relief were all either initiated or completed […]
February 8, 2018

New EPA Enforcement Guidance – “No Surprises” Approach with States

EPA’s Chief Enforcement Officer, Susan Bodine, has issued guidance on EPA and state coordination with a focus on cooperative federalism.  Interim OECA Guidance on Enhancing Regional-State Planning and Communication on Compliance Assurance Work in Authorized States, Jan. 22, 2018. Among other things, the guidance requires EPA Regional Offices to develop procedures to better communicate and […]
April 25, 2017

Sharing and Shaping the Future of EHS2 Compliance

“Sharing and Shaping the Future of Effective EHS2 Compliance” was the theme of Earth & Water Group’s EHS2 Spring Roundtable attended by EHS leaders from over 15 organizations on April 18 in Washington. E&W Spring Newsletter offers more details and insight into EHS2 compliance, regulatory trends, and enforcement risks. Recognizing that 2017 is shaping up […]