A “Wave of Citizen Suits” Under the Clean Water Act

Pick your phrase; “significant nexus,” “hydrologic connection,” or, more recently, “groundwater conduit.”  Regardless of the term, the question of whether groundwater that is “connected” to surface water (or more specifically, a “navigable” water or waters of the...

The Air Quality Manual: Help for EHS Managers

In a formal survey by the American Industrial Hygiene Association (AIHA), about 1/3 of the Environmental Health and Safety (EHS) professionals who responded said they don’t have enough staff or resources to complete their job tasks.  In the same survey, the AIHA...

Clean Water Progress and Focus by Regulators

Above all other environmental issues in the United States, clean water is most important to Americans.  Although waters in the U.S. are “dramatically” cleaner than they used to be, these gains have come at tremendous financial burden and, still, there’s much to do....

Uh Oh. We Just Found a UST.

My colleague recently took a call from an anxious small-business owner (somewhere in the Midwest).  Someone doing utility work on his property came to his office and said, “You’ve got to come outside and see what I found.” With no idea what he might find and feeling...

Transitioning from Enforcement to Compliance

A little over a year ago, we shared the Environmental Protection Agency’s (EPA) Draft Strategic Plan and that one of their three goals was “cooperative federalism” rather than a top down management/regulatory approach.  This was a significant change in the philosophy...