3M Company challenged EPA penalties for environmental violations, arguing the five-year statute of limitations in federal law didn't apply to EPA administrative proceedings. The court ruled that the five-year deadline does apply, and it starts from the date the violation occurred—not when the EPA discovered it. This matters to subcontractors because it sets a firm deadline for when agencies can pursue penalties for past violations.
The five-year statute of limitations clock starts when you violate environmental rules, not when the agency finds out about it. Keep detailed records of all compliance activities.
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