Sara Beth Watson

Of Counsel

• swatson@steptoe.com
• vCard
• Washington Office

Sara Beth Watson is of counsel in the Washington office of Steptoe & Johnson LLP, where she focuses on environmental, chemical regulatory, and occupational safety litigation and compliance counseling, including the integration of various regulatory requirements into a comprehensive compliance strategy for the regulated entity.

Practice Overview
Ms. Watson has provided compliance counseling to companies from small entrepreneurs to multi-national corporations and trade associations regarding the Toxic Substances Control Act (TSCA), the Resource Conservation and Recovery Act (RCRA), the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), the Emergency Planning and Community Right to Know Act (EPCRTKA), the Clean Air Act (CAA), the Clean Water Act (CWA), the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), the National Environmental Policy Act (NEPA), the Occupational Safety and Health Act (OSHA), the Federal Food Drug and Cosmetic Act (FFDCA), the Controlled Substances Act and various state laws such as California's Safe Drinking Water and Toxic Enforcement Act (Proposition 65).  Her work includes negotiations with federal and state agencies, administrative and federal court litigation and development of corporate and facility-specific compliance strategies.  Ms. Watson has assisted corporations in the evaluation of regulatory compliance and potential environmental liabilities related to corporate acquisitions and divestitures.  In addition, Ms. Watson has prepared comments on proposed regulations and made presentations to federal and state agencies on behalf of companies and trade associations.

Chemical and Pesticide Regulation
In the area of toxic substances, Ms. Watson has counseled clients on TSCA compliance strategies, defended TSCA enforcement actions, and counseled clients on various import and exports issues under TSCA, FIFRA and the Chemical Weapons Convention.  She also has advised clients on various compliance issues related to EPCRTKA and California's Proposition 65.

Ms. Watson has assisted companies with all phases of pesticide registration and re-registration including data development and data compensation.  She has successfully negotiated with EPA regarding the threatened suspension of pesticide registrations and stop sale orders.  She also routinely works with various state pesticide regulatory agencies including the California Department of Pesticide Regulation.  Ms. Watson represents individual pesticide registrants and trade associations in matters related to registration, manufacture, labeling, packaging, transportation and marketing of pesticides and other regulated chemicals, including the impact of state laws.  In addition, Ms. Watson has assisted clients in addressing hazardous waste issues related to pesticide manufacturing and use.

Ms. Watson also has worked with clients to comply with various regulatory requirements for studies involving human subjects including protocol development, informed consent and institutional review board and regulatory review.

Food, Dietary Supplements, Drugs and Controlled Substances
Ms. Watson has provided compliance assistance to companies regarding the Food and Drug Administration (FDA) regulation of drug excipients, medical devices, direct and indirect food additives and dietary supplements, as well as FDA and US Department of Agriculture food package labeling regulations.  She also has provided compliance assistance regarding regulation of controlled substances by the US Drug Enforcement Administration including reverse distribution and destruction of controlled substances.  She also advises clients on pharmacy registration and distribution regulations.

Hazardous Waste Regulation and Site Remediation
In the area of hazardous waste, Ms. Watson has assisted clients in evaluating the application of RCRA to various situations, developed compliance strategies and negotiated with regulators regarding various enforcement matters.  She has negotiated Administrative Consent Orders regarding remediation under RCRA and has participated in actions regarding hazardous waste identifications.  She also has assisted company environmental managers in developing and implementing RCRA audit and compliance procedures.  In the CERCLA area, Ms. Watson has been involved with investigation, allocation and remediation issues at a variety of sites ranging from multi-party disposal sites to operating production facilities.  Ms. Watson has served as court-appointed third-party liaison counsel in a CERCLA enforcement and recovery action involving more than 200 parties and as counsel to a group of de minimis parties, who obtained one of the early de minimis settlements in USEPA Region 2.

Transactions and Facility Siting
In the transaction area, Ms. Watson has provided advice on environmental issues and potential risks to a wide range of clients on transactions including real property acquisition, asset purchases, mergers and other acquisitions.  She also has worked with corporate and tax counsels to develop corporate structures that best serve the needs of new entities.  She has assisted clients with NEPA and SEPA compliance issues related to federal and state permitting of linear projects, such as railroads, and with facility siting.  She also has assisted clients with Section 404 permitting issues and historic property (cultural resources) issues.

Ms. Watson recently served as a resource member to the EPA's negotiated rulemaking on All Appropriate Inquiry on behalf of the ABA Section of Environment, Energy and Resources (SEER).  She also was an advisor/observer to the Uniform Environmental Covenants Act drafting committee.

Worker Protection Issues
Ms. Watson has developed OSHA compliance strategies and citations response strategies including negotiations with Area Administrators, Regional Department of Labor solicitors and Department of Labor headquarters officials.  She also has defended companies in administrative hearings.  Her experience in the OSHA area includes chemical exposure issues and mechanical issues.  She also has worked with companies on integrating compliance programs that address federal OSHA and state issues such as California's Proposition 65.  In addition, she has assisted clients in the development of worker health and safety studies and their submission to and use by regulatory agencies.

Noteworthy

• Ms. Watson has written and lectured extensively in the areas of transactions, chemical regulation, hazardous substances, worker exposure, and ethics in environmental issues.

Select News & Events

• 18 Steptoe Attorneys Selected for Who's Who Legal
• Sara Beth Watson Clarifies Brownfields 2005
• Sara Beth Watson Publishes on Cleanups
• ABA Section of Environment Energy and Resources
• Sara Beth Watson in ABA Teleconference on EPA’s 'All Appropriate Inquiries' Final Rule, November 16, 2005
• Sara Beth Watson on Waste Streams Panel, February 22, 2005
• Can I Really Get Liability Relief from the 2002 Brownfield Amendments and What is UECA?, March 12, 2004, 33rd Conference on Environmental Law
• Environmental Due Diligence: State of the Art of Negotiating Environmental Issues in Energy Industry Purchase and Sales Agreements, February 20, 2004, 35th Annual Program on Oil and Gas Law, Institute for Energy Law
• Sara Beth Watson Speaks at Energy Security Conference, February 19, 2004
• Emerging Liability Issues Under the New Brownfields Law, November 14, 2002

More Seminars & Events »

Publications

• All Appropriate Inquiry
  The New Rules
  November 16, 2005, ABA Teleconference
• Bona Fide Prospective Purchasers Cleaning Up Their Own Property
  November 4, 2005, Brownfields 2005 EPA National Conference
• Let's Talk Dirty: How Government Regulators Have Helped and Hindered Redevelopments of Contaminated Property
  December 14, 2004
• Liability Relief Under the Brownfield Amendments—The Continuing Story
  September 21, 2004
• Environmental Issues in the Siting of Power Generating Facilities
  American Bar Association, Section of Environment, Energy and Resources, ETAB Newsletter
  November 1, 2001
• Ethical Issues in Environmental Law
  April 2001, 152 The Environmental Counselor 10
• Environmental Issues in Transactions: Old Swamps and New Bridges
  September 2000, 15 Natural Resources & Environment 2
• Assessing Conflicts of Interest at Multi-Party Superfund Sites: From First Involvement to Litigation
  June 1998, 12 The Environmental Lawyer 3

More Publications »

Professional Affiliations

• American Bar Association
• Section of Environment, Energy and Resources Council (2003-2006); Chair, Environmental Transactions Audits and Brownfield Committee (2000-2002); Co-Chair, RCRC/CERCLA Update (1998-1999)