Hey, how many of you are at Surfaces this week? Be sure to come by the NWFA booth and tell Stacy how much you love the blog. Complain to Michael that you just don’t get enough formaldehyde rants. Check in with Anita and demand more TSCA Training. And of course if you see me, say hi, because I know Michael and Anita won’t be talking to me….
And then why don’t we plan to get together again in a few weeks in North Carolina. For what you ask?
Well, you know the differences between the three major enforcements of Lacey, right? And you know about EAPA and transshipment and circumvention? And what “origin” means to the government? You’re up on TSCA and FCPA and what is covered under Section 307 of the Tariff Act of 1930 (19 U.S.C. § 1307)?
If any of those questions have you blinking in confusion, you might look at attending the IWPA’s Due Diligence Training in North Carolina and the IWPA’s convention in Arizona. There’s not a lot of time to register for the first one, sorry
In North Carolina, there will be three classes—the original introductory course, the “201” level—advanced training—and then “audits,” which is obviously about creating an audit program. The 201 course will be repeated prior to the convention as well. I would not recommend anyone take 201 before they’ve done the original introduction: you want to know what a PPQ 505 is and how to fill it out before you know how filling it out wrong could be a misdemeanor in one situation or a felony in another.
I know I talk a lot about compliance education and building a program for your business and I know it’s tough. But it’s necessary. These regulations aren’t going to go away. So learn about them now, voluntarily, before the government mandates it of you in an enforcement action.




