Gregory S. Narsh is of counsel in the Detroit and Harrisburg offices of Pepper Hamilton LLP, where he is a member of the Environment and Energy Practice Group in the Litigation and Dispute Resolution Department. Mr. Narsh’s national practice is focused almost exclusively on regulatory environmental, safety and health and transportation matters. He also is a Fellow of the Pepper Center for Public Service.
Mr. Narsh, formerly a chemical engineer, spent 12 years in the chemical industry at Monsanto Company, where, for more than eight years, he was in charge of safety and/or environmental compliance at a large chemical manufacturing facility. Over the last 30-plus years, Mr. Narsh has gained considerable experience with Occupational Safety and Health Administration (OSHA) matters at both the federal and state levels through his comprehensive national practice in this area. He has represented and advised clients in approximately 40 states, including large and small commercial and industrial entities, as well as construction companies, health care providers and service providers, in connection with OSHA compliance and enforcement matters. Typical engagements include advising clients on OSHA compliance generally, or in connection with OSHA inspections, as well as negotiating OSHA citations and penalties — from the informal hearing stage through litigation, if necessary. He has tried several cases before the Occupational Safety and Health Review Commission (OSHRC) and negotiated numerous settlement agreements, some nationwide in scope. He has handled more than 50 workplace fatality cases. He has also assisted clients with self-audits, both as an auditor and as a reviewer of audit reports performed by consultants.
Mr. Narsh’s practice also covers matters before numerous administrative agencies, including all areas of state and federal environmental law (air, water and waste). He has successfully negotiated compliance and penalty issues with the U.S. Environmental Protection Agency (EPA), OSHA, the Mine Safety and Health Administration (MSHA), and the Department of Transportation (DOT) (including agencies that implement DOT regulations, such as the Federal Aviation Administration and the U.S. Coast Guard), as well as with state equivalents of these agencies in numerous states. In addition to general compliance matters, he has experience in handling state and federal Superfund matters, hazardous waste issues and underground storage tank matters. Mr. Narsh has represented both small and large corporations, as well as municipalities. He has been counsel of record and/or appeared before state administrative agencies, state courts and the EPA’s Environmental Appeals Board in Washington, D.C. He has also represented clients before state and federal agencies in connection with environmental/criminal investigations.
Mr. Narsh’s practice also includes assisting with acquiring and defending administrative permits and with due diligence and negotiation of safety and environmental aspects of large mergers and acquisitions.