Mathew Todaro of Verrill Law joins us for a third time in this episode - this time to talk about EPA's General Duty Clause (GDC). In this episode, Mat, an attorney that specializes in enforcement defense, provides an overview of the objectives of EPA's GDC. But with such broad language and no specific list of covered substances, what are the real requirements for facilities when it comes to this GDC? And with so many similarities between the requirements of PSM/RMP and the GDC, are there even advantages for a facility to keep less than the threshold quantity of a hazardous substance that would require a PSM/RMP program? Mat and Rob cover the answers to these important questions and more in this episode. 

Find the GUIDANCE FOR IMPLEMENTATION OF THE GENERAL DUTY CLAUSE CLEAN AIR ACT SECTION 112(r)(1) here: https://www.epa.gov/sites/default/files/documents/gendutyclause-rpt.pdf 

Be sure to check out Mat's previous appearances on our podcast by listening to episodes 25 and 35. Connect with Mat on LinkedIn here.