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May 22, 2024
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Legal Issues for RPMs and OSCs
Hosted by U.S. EPA
Office of Superfund Remediation and Technology Innovation

Legal Issues for RPMs and OSCs is a full-day training course designed to instruct RPMs and on entry to private property to implement Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) response actions and on efficiently managing site records. Issues to be covered include (1) sources and limitations on entry authority under the U.S. Constitution (due process, takings and free speech), CERCLA and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP); (2) preparing to seek consent to enter from property owners; (3) tools used to document consent; (4) defining what constitutes a record; and (5) tips for managing email. An RPM or OSC’s failure to address the legal issues surrounding entry to private property and to maintain site records may lead to significant adverse consequences for the government and, in certain instances, the RPM or OSC. These consequences may include loss of opportunities for cost recovery, claims against the government, and personal lawsuits against the RPM or OSC. The information presented in this course instructs RPMs or OSCs on the proper procedures for obtaining access under a wide range of circumstances and the importance of keeping site records organized and up-to-date. By taking the course, participants:

  • Learn the role of the U.S. Constitution, CERCLA, the NCP, delegation, guidance and site-specific documents in obtaining access to private property to conduct work under CERCLA.
  • Understand the process for obtaining and documenting access to private property under a variety of conditions including, but not limited to, when an owner is uncooperative.
  • Understand the role of the EPA counsel in assisting the RPM and OSC in efforts to lawfully obtain access to private property.
  • Learn the importance of managing site records, including email, to support successful cost recovery actions.

Registration for this training is open to U.S. EPA employees ONLY. 

Important Notice: Due to the content presented during a CEC course and the restrictions in place for non-citizens to enter federal buildings, international attendees are not permitted to attend CEC courses.

For general information contact Jodi McCarty (ICF) by telephone at 773-934-3091 or via e-mail at

 Upcoming Events

  • New York, NY
    November 13, 2024

Previous Events (click to view/hide)
Bullet  San Francisco, CA
Postponed - Event Details
  July 14, 2016 - July 14, 2016
Bullet  Boston, MA
Postponed - Event Details
  May 26, 2016 - May 26, 2016
Bullet  Chicago, IL
Postponed - Event Details
  March 8, 2016 - March 8, 2016
Bullet  Seattle, WA
  February 11, 2014 - February 11, 2014
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