Enforcement reporting requirements

This book provides and overview of SARA Title III compliance requirements. Notification and reporting requirements, enforcement and penalties, trade secret protection provisions, and other aspects of the law are detailed. 

One of the more powerful deterrents that the U.S. FDA uses is adverse publicity. The U.S. FDA has no authority to require a company to advertise adverse publicity, but it does publish administrative actions against a company in any number of federai publications, such as the Federal Register, FDA Enforcement Report, FDA Medical Bulletin, and FDA Consumer (35). 

Consolidating and enforcing pipeline reporting requirements to improve price transparency and more effectively monitor the exercise of market power. 

See Chapter 7, Reporting and Recordkeeping for a discussion of enforcement of reporting requirements concerning PEOA. Tlieie have been three SNURs issued for PEAS. Action Plan PECs, 1. 

There is no required procedure for self-reporting under the Enforcement Response PoHcies. However, a written self-report is critical for the company s proof of compHance with the self-reporting requirements. If a self-report is faxed to the EPA, a company should keep a printout of the transmission confirmation from the fax machine to show that the fax was indeed sent. If the self-report is sent by Federal Express or Express Mail, the company should get a dehvery confirmation and keep it in the file together with the self-report. An oral report should be confirmed in writing. These items are proof of the... 

In administering this chapter, the Administrator shall consult and coordinate with the Secretary of Health and Human Services and the heads of any other appropriate Federal executive department or agency, any relevant independent regulatory agency, and any other appropriate instrumentahty of the Federal Government for the pinpose of achieving the maximum enforcement of this chapter while imposing the least burdens of duplicative requirements on those subject to the chapter and for other purposes. The Administrator shall, in the report required by section 2629 of this title, report annually to the... 

These obligations to keep records extend to include the self-employed even though there may be no duty on him to report accidents. These records must be kept readily available and be retained for at least three years. If the enforcing authorities require it, copies of these records must also be sent to them. 

Bartrip and Burman (1983 37 ff.) explain the difficulties of getting accurate statistics of railway accidents and injuries. For example, only a restricted range of accidents need be reported, the reporting of accidents was haphazard, and the Inspectorate lacked the powers to enforce the reporting requirements. 

The primary purpose of both CERCLA and EPCRA release reporting requirements is to notify various levels of government of potential hazards so that the necessary response actions can be taken in a timely fashion to ensure maximum protection of human health and the environment. EPA does not necessarily take enforcement action against releasers, but may take action against those who fail to provide the required notification. These notifications assist EPA in identif5dng releases that may eventually require a Superfund removal action or a long-term remedial cleanup. 

Despite its low profile in the EPA, TSCA fines collected for violation of this complex scheme of chemical regulation have often exceeded those collected under the Resource Conservation and Recovery Act, the Comprehensive Environmental Response, Compensation and Liability Act, the Clean Air Act and the Federal Water Pollution Control Act. Much of this enforcement is centered on the information collection and reporting requirements of TSCA. Mixtures are not chemical substances under TSCA however, all ingredients within a mixture can be defined as chemical substances. Articles are not considered chemicals under TSCA. The incorporation... 

The OSHAct starts in Section 2 and contains congressional findings. Due to excessive injuries and illnesses, employers now have specific responsibilities regarding occupational safety and health (OS H). It is the responsibility of the Secretary of Labor to institute OSHA. He or she will oversee the development and implementation of workplace health and safety standards, including any research and training required, as well as ensure the enforcement of OSHA standards, entice states to become involved, develop reporting requirements for injuries and illnesses, and foster joint labor/ management efforts for OS H. 

Again, where the employer s reporting requirements are unreasonable, unduly burdensome, or enforced with unjustifiably harsh sanctions, they may result in inaccurate injury records. 

Anhydride has been used for the illegal manufacture of heroin [561-27-3] (acetyknorphine) and certain other addictive dmgs. Regulations on acetic anhydtide commerce have long been a feature of European practice. After passage in 1988 of the Chemical Diversion and Trafficking Act, there is also U.S. control. Orders for as much as 1,023 kg acetic anhydtide, for either domestic sale or export, require a report to the Department of Justice, Dmg Enforcement Administration (54). 

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