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Jennifer M. Tharp
Senior Associate
Jennifer Tharp is a senior associate in the Environmental, Safety & Health Practice. Jennifer’s practice focuses on complex regulatory decision-making and risk management in the intersection of environmental compliance, product stewardship in the healthcare and chemical sectors, as well as automotive safety. Her experience leverages relationships across practice groups at Squire Patton Boggs, and her unique background in environmental and healthcare policy to provide clients a full-service approach to risk counseling, as well as the supporting “glue” to keep supply chains moving in a dynamic regulatory environment.
In particular, Jennifer has developed expertise guiding international and domestic automotive industry clients, and their supply chain partners, through federal regulatory requirements under the Clean Air Act, the National Traffic and Motor Vehicle Safety Act (the Safety Act), the Motor Carrier Safety Improvement Act, related state laws and laws associated with the transport and management of hazardous goods.
With both the breadth and depth of coverage, Jennifer and her team at Squire Patton Boggs can work with you to develop strategies for the entirety of product lifecycles from initial prototypes to end-of-life management and transportation pathways. Representative examples include collaboratively applying federal motor vehicle safety standards (FMVSS) to client engineering solutions; navigating certification and permitting requirements for vehicle and engine manufacturers; and guiding clients through recalls and mandated disclosures to federal and/or state regulators.
Jennifer is also an integral part of the Life Sciences Industry Group and regularly advises clients on a variety of Food and Drug Administration (FDA) regulatory matters for food, dietary supplements, medical devices and cosmetics. Initiatives included spearheading the firm’s response to the COVID-19 pandemic and guiding clients through emergency use authorizations, enforcement discretion and the resulting transition period.
Jennifer has been published in Lexology, Law360 and the Journal of Legal Medicine. She is a member of the Association of Women in the Metals Industries (AWMI) and a member of the Food and Drug Law Institute (FDLI). She recently co-chaired the Ohio State Bar Association’s 40th Annual Environmental Energy and Natural Resources Conference. She also recently served as a board member of Playhouse Square Partners in Cleveland, Ohio.
Environmental Compliance Counseling
- Providing guidance to engine manufacturers regarding compliance with US Environmental Protection Agency (EPA) and California Air Resource Board (CARB) environmental regulations.
- Providing advice to engine manufacturers regarding disclosures of auxiliary emission control devices (AECDs).
- Advising an engine manufacturer regarding voluntary recall campaign for emission-related engine components in coordination with EPA.
- Providing advice to clients in the iron and steel mining industry on permitting and regulatory compliance under the Clean Air Act.
- Advising municipalities on compliance with NSPS and RICE MACT.
- Providing guidance on transportation-related challenges under the Pipeline and Hazardous Materials Safety Administration (PHMSA), including importation, labeling, hazard classification, vehicle construction and more to clients in the automotive and chemicals industries.
- Analyzing Federal Motor Vehicle Safety Standards (FMVSS) and working collaboratively with client engineering teams to ensure compliance.
- Guiding clients through recalls with the National Highway Traffic Safety Administration (NHTSA) from initial Part 573 reporting through to quarterly reporting and external-facing communications.
- Working with clients to provide comprehensive Motor Vehicle Safety Act and TREAD Act training, including preparation and review of regulatory submissions.
- Advocating for clients through comments and advocacy, particularly where existing standards may not capture innovative technologies.
- Managing risks associated with the manufacture of trailers and heavy-duty motor vehicle equipment.
- Advising on nutritional labeling requirements for food and dietary supplements regulated by the Food and Drug Administration (FDA).
- Advising on regulatory matters and providing audits of policies for medical device manufacturers.
- Analyzing labeling and related marketing materials for automotive and chemicals products.
- Guiding clients through extended producer responsibility (EP) requirements associated with products in the North American supply chain.
- Advocating for clients in the mining industry on hazardous air pollutant regulations.
- Assisting with negotiation and resolution of federal and state enforcement allegations under the Clean Air Act, including consent decrees with US EPA and the Department of Justice (DOJ).
- Serving as part of a team as counsel to the independent Monitor appointed by the DOJ for a government investigation in the automotive industry.
Education
- University of Virginia, J.D., 2017
- Carnegie Mellon University, M.S., Health Care Policy and Management, Highest Distinction, 2014
- Carnegie Mellon University, B.S., Phi Beta Kappa, 2013
Admissions
- Ohio, 2017
Memberships & Affiliations
- Member, Ohio State Bar Association
- Member, Cleveland Metropolitan Bar Association
- Member, Playhouse Square Partners
- Member, Association of Women in the Metals Industries, Cleveland Chapter
- Member, Food and Drug Law Institute
- Recognized as a Rising Star in Ohio for Environmental, Food & Drugs law by Super Lawyers (2023 - 2025)
- Co-Chair, Ohio State Bar Association 40th Annual Environment, Energy and Natural Resources Conference, OSBA, March 27-28, 2025.
- Co-Presenter, “How to Navigate a Failed Stack Emissions Tests – Technical and Legal Considerations Before, During, and After the Test,” Association for Iron & Steel Conference, 2023.
- Speaker, “Mobile Source Regulation: A Primer on Navigating Emissions and Vehicle Safety Requirements,” Ohio State Bar Association 37th Annual Environment Energy and Natural Resources Conference, OSBA, 2022.
- Speaker, “Perspectives on Evolving Regulatory Landscape for US Food and Beverage” webinar, Food and Drink Federation, November 29, 2022.
- Author, “Mobile Emission Sources May Face More CAA Citizen Suits,” Law360, August 1, 2019.
- Author, “Stark Law and the Affordable Care Act: Bridging the Disconnect,” 35, Journal of Legal Medicine, no.3, 2014, at 433-444.