Two different sets of rules
Outdoor emissions from a facility are mainly governed by the federal Clean Air Act, which in New York is largely administered by the Department of Environmental Conservation under authority from EPA. Facilities may need an air permit before building or modifying equipment, and larger sources often need a comprehensive operating permit under what is called the Title V program. Smaller sources may qualify for state registrations or exemptions, depending on what they emit and how much. Air inside the workplace is a separate matter, handled mainly under OSHA, which sets exposure limits for specific substances. A business can be in good standing on one side and have problems on the other.
Where facilities run into problems
Common trouble points include changes to equipment made without checking whether a permit modification was needed, monitoring or recordkeeping that lapsed, and reports filed late or incompletely. Neighbors' complaints about odor or dust can prompt an inspection. In the workplace, ventilation problems, new materials, or renovation work can raise exposure questions. If you receive a notice of violation, it often carries a deadline to respond, and the way the first response is written can affect how the matter is resolved. Self-disclosure of a violation is sometimes an option, and the policies on it should be reviewed before deciding.
How a review starts
We look at your existing permits and registrations, emissions data, monitoring and maintenance records, and any correspondence with DEC or EPA. We ask what has changed at the facility since the permits were issued. If there is an open enforcement matter, we review the allegations and the response deadline first. For workplace air questions, we look at exposure monitoring, safety data sheets, and employee complaints, and coordinate with an industrial hygienist where needed. Technical consultants often do the measurements; our role is to connect the findings to the legal obligations and the response.
