Representative Matters
Heidi’s recent experience includes counseling clients regarding:
- Establishing and implementing comprehensive EHS auditing programs and compliance assessments nationwide, and developing corrective actions to improve operations, prevent recurrence, and minimize the risk of potential enforcement actions or other liabilities.
- Representing a leading chemical manufacturer with conducting environmental audits of a number of recently-acquired manufacturing facilities across the U.S., including providing legal interpretation of audit findings, developing appropriate corrective action measures, and disclosing the findings and corrective actions under EPA’s New Owner Audit Policy.
- Advising a broad range of companies on various OSHA and state equivalent requirements, including electrical safety, lockout/tagout (LOTO), process safety management (PSM), hazard communication, machine guarding, permit-required confined spaces, fall protection, ladders, hearing conservation, respiratory protection, and PPE requirements, among others.
- Successfully defending federal and state OSHA enforcement actions involving alleged worker health and safety violations, worker injuries, and fatalities, including:
- Negotiating OSHA’s withdraw of a citation against a chemical manufacturing plant following a fatality at a multi-employer worksite.
- Negotiating a favorable settlement of a state OSHA citation against a waste-to-energy company for alleged violations of hazard communication, respiratory protection, lead, inorganic arsenic, and cadmium requirements.
- Representing a client in an appeal of a state OSHA citation alleging walkway violations, and negotiating a favorable settlement.
- Negotiating OSHA’s withdraw of a citation against a technology company following injuries from an arc flash incident.
- Assisting clients with preparing for and responding to OSHA inspections and investigations.
- Advising a technology company with the development, implementation, audit, and ISO 14001 certification of its environmental management system (EMS) for its data center operations.
- Serving as a member of the U.S. Department of Justice-appointed Independent Corporate Compliance Monitor and Auditor team in connection with the Volkswagen AG emissions proceedings.
- Advising an automotive parts manufacturing client with identifying federal and state permit transfer requirements associated with the acquisition of a number of manufacturing facilities across the U.S.
- Defending a manufacturing company in a Clean Air Act enforcement action resulting in entry of a consent decree and denial of intervention, assisting the company with complying with the CD requirements and implementation of the SEP, and defending an administrative action challenging one of the plant’s air permits.
- Advising companies with preparing strategies for, pursuing and complying with federal and state Clean Air Act preconstruction and operating permits, complying with and determining the applicability of various Clean Air Act standards, and preparing comments on proposed rules, including revisions to National Ambient Air Quality Standards (NAAQS).