Regulation of hazardous air pollutants under section 112 of the Clean Air Act Amendments of 1990

Title III of the Clean Air Act Amendments of 1990 (CAAA or 1990 Act) completely changed the regulation of hazardous air pollutants under section 112 of the Act. These amendments, now almost four years old are becoming the cause of intense activity as the Environmental Protection Agency (EPA or Agency) and industry scramble to comply with the rigid schedule and standards mandated by Congress. This paper will analyze current section 112, its predecessor and the regulatory activity that has resulted from the amendment of the Act.