Paul C Sarahan

Practice Areas

- Environmental

- Transportation

- Safety

Career

Paul Sarahan focuses his practice on environmental, safety, and transportation issues. He has more than 25 years of experience in policy, regulation, and commercial use of the environment and has represented clients in the energy, chemical, manufacturing, transportation, and retail industry sectors before federal, state, and local agencies. Key experience includes providing regulatory counseling, advising clients on environmental auditing and permitting, and representing clients in Superfund cost recovery and remediation cases.

Professional Memberships

State Bar of Texas

- Environmental & Natural Resources Law Section, Council Member, 2020-present

- Administrative & Public Law Section

Austin Bar Association

- Environmental Law Section

- Equity Committee

American Bar Association

- Section of Environment, Energy & Resources (SEER)

Texas Bar College

The University of Texas, Chancellor's Council

Publications

PHMSA Proposes Rule Revisions for Hazardous Liquid Pipelines, Holland & Knight

Alert (2020)

• Top 10 Things You Should Know About PFAS: Real Estate and Corporate Due Diligence,

Holland & Knight's Energy and Natural Resources Quarterly Newsletter: Spring 2020

• TCEQ Guidance on Enforcement Discretion Requests for Operational Noncompliance Tied to

COVID-19, Holland & Knight Alert (2020)

Michigan Workgroup Issues Health-Based Drinking Water Value Recommendations for PFAS

in Next Step Toward Establishing Enforceable Limits, Holland & Knight Energy and Natural

Resources Blog (2019)

• Fifteen States and State Associations Comment on EPA’s Draft PFAS Guidance, Holland &

Knight Energy & Natural Resources Blog (2019)

• Michigan Governor Moves to Establish Enforceable PFAS Limits, Holland & Knight Energy

and Natural Resources Blog (2019)

• EPA's New Prescription for Pharmaceutical Waste, Holland & Knight Alert (2019)

• Environmental Hazard Communications, Texas Environmental Law, Chapter 16, Thomson.

• Used Oil Regulation, Texas Environmental Law, Chapter 22, Thomson Reuters (2007-

Present)

• Environmental Ethics and the Duty to Report, Texas Oil & Gas Association (TXOGA) (2018)

• Rising Environmental Enforcement in the Food and Drug Sector: How to Stem the Tide for

Your Facility, Synergy Environmental Newsletter (2017)

• Home Grown: A Legal Guide to Starting a Nonprofit Farmers' Market in Texas, Texas C-Bar

and Texas Rio Grande Legal Aid (2016)

• Environmental Incident Response: Preparing for and Responding to the Unexpected, Client

Alert (2015)

• University Nano Labs: Assessing and Minimizing Environmental, Health & Safety Risks, CoAuthor / Journal of College and University Law (2011)

• Responding to NIOSH's Nanomaterial Exposure Limits, Client Alert (2011)

• Emerging Safety Issues at University Nanomaterials Labs, Nanotechnology Law &

Business (Winter, 2009)

• Evaluating a Nanomaterial Operation's Compliance with Environmental Requirements:

Selected Environmental Audit Statutes and Policies, Nanotechnology Law &

Business (Summer, 2009)

• Auditing as a Tool for Ensuring Compliance with Nanotechnology Safety Requirements,

Nanotechnology Law & Business (Winter, 2008)

• Nanotechnology Safety: A Framework for Identifying and Complying with Workplace Safety

Requirements, Nanotechnology Law & Business (Summer, 2008)

Experience

Paul is well-versed in handling civil and criminal enforcement, permitting,

auditing, litigation, workplace safety, air quality, water rights, water quality,

waste handling and disposal, and Comprehensive Environmental

Response, Compensation and Liability Act (CERCLA or Superfund)

matters. He represents clients before TCEQ and the U.S. Environmental

Protection Agency (EPA), as well as before state environmental agencies in

Louisiana, Mississippi, Florida, Georgia, and Wyoming. Paul also has

handled matters before the Pipeline and Hazardous Materials Safety

Administration (PHMSA), U.S. Coast Guard, Federal Aviation

Administration (FAA), and Federal Railroad Administration (FRA).

• Advises companies on environmental audits, air compliance issues,

environmental regulatory interpretations (EPA, TCEQ, and Texas

Parks and Wildlife Department), the negotiation and revision of

master service agreements, nondisclosure agreements,

transportation-related regulatory interpretation (PHMSA and Texas

Railroad Commission), safety-related regulatory interpretations

(Occupational Safety and Health Administration, or OSHA)

• Assisted on a series of environmental issues, including electronic manifesting for waste

transportation and disposal, and defense of an enforcement action by the TCEQ in the wake of

Hurricane Harvey

• Representing clients in contested air permitting hearings

• Serving as a subject matter witness on environmental compliance history issues in a

wastewater permitting hearing

• Prepared comments on behalf of an industry group and testified before the EPA on the EPA's

• Represented clients in Superfund matters

• Represented a shipping company to address environmental issues with the U.S. Coast Guard

and TCEQ in response to a maritime accident

• Successfully defended a concrete company against criminal charges alleging unauthorized

discharges to water

• Represented a chemical company in handling a criminal investigation; succeeded in avoiding

criminal charges and all civil and administrative enforcement actions were dropped

• Represented a petrochemical facility in emergency response activities related to multiagency

investigations and enforcement actions

• Represented chemical facilities on FRA and FAA enforcement actions

• Represented clients with respect to Texas Public Information Act requests, requirements, and

exceptions

• Assisted buyers, sellers, and lending institutions in evaluating environmental issues, assessing

potential liabilities, and creating solutions that provide a path for transactions to proceed to

closing

• Advised on the establishment of a system for the collection, management, transportation, and

disposal of hazardous or state-regulated waste generated in association with the operation of

a grocery or pharmacy

• Advised on the applicability of Tier II hazardous chemical inventory reporting requirements to a

grocery facility

• Successfully represented a grocery store in a civil enforcement action by a local government

alleging violations of storm water and waste disposal requirements

• Advised on EPA regulation of articles under the Toxic Substances Control Act (TSCA) and the

applicability of the EPA's reporting requirements under TSCA

• Advised on the handing, collection, storage, transportation, and disposal of off-spec or

damaged products that may be subject to state or federal regulation as hazardous waste

Education