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In the Spotlight: Emergency Planning Obligations
Owners and tenants of commercial buildings sometimes fail to recognize that certain chemicals stored on-site, most notably substances used in a building's mechanical system, could trigger annual reporting obligations. For example, if a building relies upon lead-acid batteries as part of a backup power system or a battery charging station, those batteries contain sulfuric acid, lead, lead oxide and lead sulfate.
Similarly, diesel fuel (considered to be a hazardous chemical) may be used to power backup generators at the building and could be stored on-site in an above ground or underground storage tank. Keeping those materials on-site may require notification to local emergency responding agencies, as required by the federal Emergency Planning and Community Right-to-Know Act (EPCRA) as well as state and local laws. Violations of those laws, particularly EPCRA, can carry significant penalties.
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The DOJ's Corporate Enforcement Policy: One Year Later
The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
Use of Deferred Prosecution Agreements In White Collar Investigations
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The DOJ's New Parameters for Evaluating Corporate Compliance Programs
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