Counseling and Defense
Edgcomb Law Group, LLP attorneys have considerable experience in addressing the complex hazardous materials regulations (“HMRs”) governing hazardous materials transportation set forth in Part 49 of the Code of Federal Regulations. Our experience includes knowledge of the Department of Transportation’s hazardous materials regulations and includes handling the regulatory issues surrounding hazardous materials transport. Our expertise spans a wide spectrum of technical, regulatory, and policy aspects of hazardous materials transportation. We have given regulatory compliance advice to a large distributor of consumer commodity ORM-D hazardous materials, represented shippers and charterers in maritime arbitrations concerning hazardous material transportation issues, and represented shippers in regulatory proceedings involving product and crude oil pipeline issues. We have also defended a number of clients who have received agency notices of violations (NOVs) for alleged improper air and motor vehicle transportation of hazardous materials and negotiated reduced penalty assessments.
Provide compliance advice to a major consumer product distribution company regarding receipt of notice of probable violation of marking regulations.
Provide compliance advice to a major pharmaceutical distribution company regarding applicability of packaging and marking regulations to returned products destined for disposal and provide related contract drafting advice.
Defend a paint company and successfully resolve notice of alleged violation of regulations governing air transportation of hazardous materials.
Edgcomb, John D., Hazardous Substance Releases from Vessels: Current U.S. Law, the HNS Convention and its Potential Impact if Ratified, 10 Univ. of San Francisco Maritime Law Journal 73 (1998).
Edgcomb, John D., The Trojan Horse Sets Sail: Carrier Defenses against Hazmat Cargoes, 13 Univ. of San Francisco Maritime Law Journal 31 (2000-01).