ELR Citation: ELR 20987
No(s). C 91-20415 SW (N.D. Cal. Feb 12, 1992)

The court holds that a manufacturer's wholly past violation in failing to file a material safety data sheet (MSDS) for nickel and nickel compounds under §311 of the Emergency Planning and Community Right-to-Know Act (EPCRA) is not exempt from citizen enforcement under EPCRA §326, and the maximum p...