During a routine permitting action, a state permitting agency made a new determination that a federal standard regulating coating of plastic parts should apply to an automotive parts producer that has operated for years under the belief that the standard did not apply. This decision would have seriously impacted future operations at the facility and opened up enforcement exposure for past operations. Hatchett & Hauck worked closely with the client to demonstrate to both the state agency and U.S. EPA that the new interpretation was in error and that the federal standard did not apply, thereby avoiding both enforcement exposure and significant future compliance costs.