In August 2023, the United States (US) Environmental Protection Agency (EPA) announced its National Enforcement and Compliance Initiatives for 2024 to 2027. Many of these initiatives shouldn’t come as a surprise. We’ve seen an increased focus on per- and polyfluoroalkyl substances (PFAS), drinking water, and air contamination in recent years. And the EPA’s new enforcement priorities align with these priorities as expected.
Understanding the EPA enforcement priorities will help you remain compliant and avoid compliance penalties. So, let’s break down the different facets of the EPA’s enforcement priorities and provide some tips to keep your compliance program on track.
EPA Enforcement Priorities for 2024-2027
Mitigating Climate Change
The first enforcement priority for the EPA is addressing the climate crisis. They plan to focus on three areas:
- Methane emissions from oil and gas facilities
- Methane emissions from landfills
- Use, importation, and production of hydrofluorocarbons (HFCs)
The EPA has reported that they have found extensive noncompliance in these area and hope that by focusing on these priorities they will be able to reduce the emissions of greenhouse gases.
Addressing Exposure to PFAS
PFAS contamination has been an increasingly important topic in the world of chemical and environmental compliance. These “forever chemicals” persist in the environment and pose threats to human and environmental health.
The EPA’s plan is to focus on implementing their PFAS Strategic Roadmap, holding those who manufactured PFAS and/or used PFAS in the manufacturing process accountable for PFAS pollution. They want to ensure these entities properly identify PFAS that have been processed or used, control their release, and comply with any existing and future PFAS regulations.
Protecting Communities from Coal Ash Contamination
Hundreds of millions of pounds of coal ash could pose a threat to human health and the environment across the country. The EPA plans to focus on 300 coal burning facilities responsible for 775 coal ash units, helping these facilities properly dispose of and discharge coal ash.
Reducing Air Toxics in Overburdened Communities
Many communities across the country face health threats from hazardous air pollutants (HAPs) from nearby industry. The EPA plans to address this threat by investigating HAP sources and enforcing clean air compliance standards, especially in communities overburdened with air pollution.
Increasing Compliance with Drinking Water Standards
This initiative will target drinking water systems across the country to ensure they comply with the Safe Drinking Water Act (SDWA). To accomplish this, the EPA plans to increase its field presence, strengthen its compliance enforcement, and offer more compliance assistance.
Chemical Accident Risk Reduction
Chemical releases and chemical accidents can cause environmental and human health issues as well as catastrophic accidents that can result in deaths. The EPA reports that they have found substantial noncompliance in companies that handle hazardous substances. They plan to address this through stricter enforcement of existing regulations and requirements.
Tips for Your Environmental Compliance
As compliance priorities shift and expand, how can your company continue to sustainably manage environmental compliance? Below are a few tips to keep your compliance program in check.
PFAS Management
Make sure you have established a strong PFAS management program. PFAS regulations and enforcement are expected to increase in the future.
Take time to analyze your products and manufacturing processes to fully understand the PFAS they might contain. Because PFAS are so pervasive in the environment, they might be present in parts of your products or processes you don’t expect. If any PFAS are being released into the environment, take corrective action.
Understand and Meet Compliance Regulations
A key to staying compliant is to understand the environmental compliance regulations that apply to your facilities. This could range from the Toxics Substance Control Act (TSCA) and Toxics Release Inventory (TRI) reporting to having a Stormwater Pollution Prevention Plan (SWPP) and Spill Prevention, Control, and Countermeasure (SPCC) plan in place.
Environmental Monitoring
Don’t measure your environmental releases one time and assume they remain the same. You need to consistently monitor your environmental impact, including air quality, ground water quality, soil quality, sediment releases, and more.
By continuously monitoring your environmental impact, you’ll know as soon as something goes off track and be able to correct it as soon as possible instead of waiting until it becomes an obvious problem.
Internal Audits
Internal audits should be a regular part of your environmental compliance management. It’s better to find a compliance issue yourself and proactively fix it than wait for an official audit to reveal problems.
While internal audits may seem time consuming at first, in the long run they will save you time and effort.
Train Your Employees
No matter what compliance regulations and requirements you need to meet, training your employees is crucial to a successful compliance program. You need to make sure your employees understand your compliance requirements, your reporting methods, and their specific compliance tasks. Plus, some compliance requirements have mandatory training requirements, such as SPCC’s requirements for annual training.
Get EHS Compliance Support
The landscape of environmental compliance is always changing, and in recent years it can feel like it is moving at lightspeed as new environmental concerns come to the forefront.
The new EPA enforcement priorities are an indicator that environmental compliance is going to continue to grow in importance, and making sure you have a strong compliance program will be crucial to keeping your business on track.
If you need help understanding or meeting environmental compliance requirements, contact Tetra Tech’s experts at [email protected]. We can help you with everything from employee training to PFAS management to internal auditing and more. Contact us today!
