Andrea Sumits _ 400.jpg




Tel: (510) 495-1409


  • University of Texas at Austin (with honors)

  • Santa Clara University School of Law (with honors)


  • Proposition 65

  • Asbestos

  • Environmental Regulatory Compliance

  • Occupational Health & Safety Compliance

  • Product Regulatory Compliance

  • Permitting and Enforcement

  • Hazardous Materials

  • Compliance Auditing

  • Voluntary Self-Disclosures

  • EH&S Compliance Policies and Programs

  • Transactions/Due Diligence

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Andrea’s practice includes environmental, health and safety (EH&S) regulatory compliance, product regulatory compliance, strategic EH&S counseling, and EH&S aspects of real estate and business transactions.  She advises domestic and international clients in the real estate, consumer products, automotive, electronics, medical device, biotechnology, pharmaceutical, energy, and manufacturing industries. 


Andrea’s areas of expertise include Proposition 65 for both consumer products and buildings (commercial office buildings, residential rental properties, hotels & resorts, retail centers, restaurants), hazardous materials and waste, occupational health and safety requirements, environmental and EH&S aspects of due diligence and business transactions, and permit transfer issues.  She has represented numerous clients in resolving notices of violation or notices to comply, including successful penalty mitigation and even withdrawal of enforcement action.


Andrea’s Proposition 65 experience includes drafting and negotiating settlements, advising clients regarding Prop 65 testing protocols, warning language, supplier management, and compliance assurance programs.  In the context of buildings and real estate, Andrea counsels clients on Prop 65 warnings and testing, as well as drafting Prop 65 and related hazardous materials provisions, disclosures, and notifications in tenant leases and contractor agreements.


Andrea has special expertise advising clients on all aspects of Cal/OSHA compliance, including the preparation of Injury and Illness Prevention Plans.


Andrea has extensive  experience with asbestos rules and regulations. Her expertise in this field includes counseling clients, planning and executing demolition and renovation projects, allocation and documentation of asbestos compliance responsibilities between various contractors on a project, reviewing and preparing asbestos-related documents such as O&M plans or Asbestos Management Plans, standard operating procedures, asbestos survey reports, and agency notifications and reporting. In addition, Andrea represents clients in connection with notices to comply, notices of violation, citations, and other enforcement actions relating to alleged asbestos violations.


Andrea also has specialized expertise in the development and implementation of EH&S compliance- and performance-oriented management systems, with a particular focus of aligning programs with external legal criteria such as the federal sentencing commission, EPA, and DOJ guidelines developed for penalty mitigation.  She has helped many clients achieve ISO 14001 certification, and establish effective EH&S compliance management systems.

Prior to joining Environmental General Counsel LLP, Andrea developed her practice at several mid-size and large law firms, including Pillsbury Winthrop, Beveridge & Diamond, and Holland & Knight.