Automotive Supplier's Surprise Inspection
An automotive parts supplier client was subject to a surprise visit from the MDEQ Waste Management Division. The client's environmental manager had only been in his position for six weeks at the time. Following the inspection, a letter was sent listing ten compliance issues. The client's environmental manager did not recognize this as a letter of violation and missed the 30-day response deadline.
Varnum became involved and directed the preparation of a complete response to each issue, in a way that did not constitute an "admission" of non-compliance. Upon the law firm's recommendation the client obtained an extension of time to respond, corrected eight of the ten issues, and prepared a compliance schedule for the remaining two issues. The carefully drafted response letter was sent to the MDEQ, and no enforcement action was taken.