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.
Elizabeth Baldwin is Environmental Compliance Officer for Metropolitan Hardwood Floors. In her 25 plus year career in the wood industry has visited over 70 countries and hundreds of facilities of all sizes and types. She describes herself as a “jack of all wood trades.” Familiar with jungles of all sorts–having camped out along the Amazon and walked the halls of Congress–she blogs for the NWFA on both environmental and regulatory issues for educational and informational purposes only. Her blog is not intended and should not be construed as legal advice. Persons seeking legal advice on compliance with CARB, TSCA, the U.S. Lacey Act or any other law, regulation, or compliance requirement/claim should consult with the regulatory agency directly and/or a qualified legal professional.