Trent Doyle advises clients on environmental, transportation, and risk management matters including compliance with US and international chemical control laws, hazardous materials regulations, and all aspects of the Toxic Substances Control Act (TSCA). The depth and breadth of Trent’s understanding of environmental and transportation laws enables him to support companies up and down the value chain on product stewardship and facility-based issues.
He counsels companies on product testing, classification, packaging, and labeling to address the requirements of the US Department of Transportation (DOT) hazardous materials regulations and international counterparts (ICAO/IATA, IMDG Code, ADR, etc.). He secures government approvals, special permits, and letters of interpretation and represents shippers in investigations and enforcement cases involving the Pipeline and Hazardous Materials Safety Administration (PHMSA), the Federal Aviation Administration (FAA), and other modal administrations and agencies. Trent has extensive experience in advising companies on the transport of products ranging from bulk industrial chemicals to personal care products and lithium batteries.
Trent advises businesses on their environmental compliance management and product stewardship programs. He helps companies prepare for agency inspections, respond to letters of investigation and data requests, and manage communications with regulatory authorities, customers, and other stakeholders. He conducts regulatory compliance audits and helps clients obtain relief under EPA's Audit Policy and state audit/self-disclosure laws and policies.
Trent serves as counsel to chemical industry trade associations, providing strategic legal advice on legislative, regulatory, and public policy issues.
Prior to practicing law, Trent worked as an environmental engineer and consultant and prepared numerous air permit applications, emission inventories, environmental impact statements, and compliance plans for a wide range of industrial facilities. He leverages this experience and technical background in working with a client’s business team/consultants to serve as a trusted legal advisor who can recommend practical solutions to pressing challenges.
- Negotiated first enforceable consent agreement (ECA) under TSCA for environmental monitoring and represent consortium of companies in providing EPA with draft risk evaluation and request for a manufacturer-requested risk evaluation under TSCA
- Represented chemical importer in EPA investigation of CDR reporting practices and negotiate favorable resolution of alleged violations
- Successfully petitioned the UN Committee of Experts on Transportation of Dangerous Goods to remove Division 6.1 classification from listing for substance in UN Model Regulations. Obtained US DOT support for petition and ultimate removal from DOT regulations and counterparts around the world
- Worked with client to obtain reversal of PHMSA decision to deny special DOT permit for landmark cylinder testing and life extension technology
- Negotiated favorable settlement of FAA enforcement action involving small package consumer product shipments
- Represent pipeline operator in PHMSA investigations and enforcement actions resulting from spill incidents. Provide counsel on compliance inspection practices and procedures
- Reviewed and advised motor carriers on Hours of Service and FMCSA regulatory compliance programs and benchmarking against best practices
- Defended facility operator in EPA CAA New Source Review enforcement action and obtained favorable resolution that facilitated continued operation
- Provided long-term support to food manufacturer in developing and implementing air permitting strategy at multiple facilities that provides for operational flexibility while achieving corporate compliance and sustainability goals
- Conducted audit of Emergency Planning and Community Right-to-Know ACT (EPCRA) reporting practices and procedures for multi-facility operator, self-disclose and correct reporting omissions/issues and obtain full penalty mitigation under EPA’s Audit policy
- Provided training to corporate team on hazardous materials compliance obligations impacting product design/labeling/packaging; reviewed portfolio of personal care products and advise on shipping options and opportunities for regulatory relief
- Obtained DOT PHMSA approval for new explosive and self-reactive materials for transportation.
- Advised chemical product manufacturer on transportation packaging, labeling, and approval obligations and opportunities for roll-out of new product to multiple destination countries.