CLFMI contracted with an environmental law firm which petitioned the EPA to allow CLFMI Member Companies to file a Group Permit, rather than a separate permit for each manufacturing facility (some CLFMI member companies had dozens of facilities). In order for this Group Permit to be considered, the EPA required the industry (via CLFMI) to verify that there were enough similarities among the various facilities to determine that testing at a representative number of geographically diverse sites would be adequate to identify the potential problems and to determine the appropriate steps necessary to correct the those problems.
CLFMI member firms which were to be included in the potential group shared the cost of applying for the permit on a proportional basis. In addition, member firms donated hundreds of hours of labor to help produce the documentation needed to establish the required verification of similarity, as well as to meet with legal counsel and EPA representatives.
The result was an EPA acceptance of the CLFMI Group Permit. One member firm estimates that the Group Permit saved it nearly $80,000 in testing costs, paperwork compliance, and personnel costs.