Regulatory Responsibilities during COVID-19
The ongoing COVID-19 pandemic has caused many businesses and industries to alter their work habits and schedules (i.e., quarantine, work-from-home, and time/spatial restrictions). Accordingly, your business may face challenges in fulfilling certain routine regulatory requirements including, but not limited to:
- SPCC tank inspections
- RCRA hazardous waste inspections
- Solid waste inspections and monitoring
- Visual air emissions monitoring
- Groundwater monitoring and sampling
In recognizing these compliance challenges, the USEPA has relaxed certain regulatory compliance requirements during this unprecedented event until such time that we may return to business as usual. EPA’s policy concerning COVID-19 regulatory impacts is described in a memo dated March 26, 2020, and retroactively applies to activities beginning March 13, 2020. A copy of this memo can be found here: EPA Memo March 26, 2020. The regulated community is encouraged to maintain their compliance, recordkeeping and reporting to the best of their abilities during this time. This may include altering inspection/monitoring/sampling schedules (e.g. quarterly or semi-annually), abbreviating inspections/monitoring to the most critical components, maintaining internal vs. external reporting, etc.
With any changes to a facility’s regulatory compliance protocol(s), the facility is advised to document such temporary revisions to explain the rationale of the modification by any appropriate means including:
- Making appropriate notes in routine inspection forms;
- Formal amendment of associated plans (i.e., SPCC Plan, SWPPP, O&M Manuals, etc.); and
- Drafting a memo to the inspection file(s).
Should your facility require any assistance to augment your environmental compliance staff during this unprecedented time, Aegis has many experienced, qualified staff available to help you. Secondly, should you need assistance amending plans and/or procedures, or drafting formal correspondence for your regulatory compliance files, please contact Scott Mortimer at (804) 378-6015 or smortimer@aegisenv.com.
Aegis protects you, while you protect the environment.