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Ben Patton

Houston Office

Ben Patton concentrates his practice on environmental, health and safety (EHS) regulatory and compliance matters involving major accidents, chemical releases and other workplace incidents. He routinely counsels companies in connection with major industrial accidents, crisis response, whistleblowers, process safety incidents and workplace fatalities. Ben has also advised multiple refining and chemical companies on agency investigations, environmental litigation and liability for groundwater contamination.

Ben has helped clients respond to investigations by the Bureau of Safety and Environmental Enforcement (BSEE), the US Environmental Protection Agency (EPA), the National Transportation Safety Board (NTSB), the Pipeline and Hazardous Materials Safety Administration (PHMSA), the Chemical Safety Board (CSB), the Occupational Safety and Health Administration (OSHA) and state regulatory agencies.

A significant part of Ben's practice involves counseling companies on EHS culture and the management of process safety. In the aftermath of the Deepwater Horizon incident, he advises energy companies with upstream and midstream operations on emerging regulatory requirements and systems for overseeing EHS performance. Additionally, Ben advises energy companies on the development of robust process safety management systems and procedures.

Shown below is a selection of Ben’s engagements.

  • Representation of integrated energy companies and industry groups in multiple process safety and environmental regulatory rulemakings by federal and state agencies.
  • Development of major incident response toolkits and programs for energy companies with upstream and downstream operations.
  • Representation of energy companies in connection with environmental criminal investigations.
  • Representation of a US automotive manufacturer in connection with workplace fatalities in the United States and Europe.
  • Representation of supermajor in multi-agency investigation following refinery fire, including the CSB, the EPA, OSHA, and other state and local agencies.
  • Representation of multinational automotive manufacturer in enterprise-wide compliance assurance and safety review.
  • Appeal and favorable settlement of OSHA enforcement relating to natural gas power plant.
  • Development of emergency response plan for national exploration and production company.
  • Applicability analysis and compliance review of petroleum storage assets.
  • Representation of an energy company in connection with a fire at an exploration and production site resulting in federal and state regulatory agency investigations.
  • Representation of national petroleum refiner and retailer in internal whistleblower investigation and subsequent downstream process safety review.
  • Representation of numerous chemical manufacturers and transporters in citation actions by federal and state occupational, safety and health agencies.
  • Representation of Fortune 500 offshore drilling company in numerous investigations and incident of non-compliance actions by the BSEE.
  • Representation of two multinational petroleum refiners in a nationwide docket of more than 20 active MTBE product liability and groundwater contamination cases in state and federal court.
  • Representation of a national petroleum retailer in a class action product liability suit relating to ethanol additives in gasoline.
  • Representation of a national chemical manufacturer in a breach of contract dispute concerning environmental liability for a railroad chemical spill.
  • Representation of the primary investor in the construction of a coal power plant before the EPA Environmental Appeals Board and in federal court in a suit brought by a state attorney general.
  • Representation of a large multinational parent company in a breach of software licensing and consulting agreement suit involving a dozen independently represented subsidiaries.
  • Representation of a multinational oil and gas services company in connection with a DOJ investigation into an offshore incident involving multiple fatalities.
  • Representation of a multinational electric utility company in connection with an employee fatality and investigation by federal agency.
  • Representation of an integrated oil and gas company in connection with a multi-agency investigation and enforcement following a refinery explosion and fire.
  • Representation of a national utility company in connection with the implementation of a process safety management program.
  • Representation of a vehicle manufacturer in connection with an OSHA inspection into machine guarding and other workplace safety standards, including subsequent enforcement.


Legal 500, 2017
Legal 500 US - Next Generation Lawyer, 2017
August 20, 2015
Panelist | Legal and Ethical Issues of Privilege in the Context of Internal Investigations | Association of Corporate Counsel Symposium | Houston, Texas
September 16, 2014
Presenter | RFI and Improving the PSM Standard | Chemical Safety and Security Seminar | Houston, Texas
June 4, 2014
OSHA Enforcement Focus: RAGAGEP | 27th Annual Environmental, Health & Safety Seminar | Galveston, Texas
June 1, 2013
Speaker | Preparing for the Chemical NEP | Texas Chemical Council/Association of Chemical Industry of Texas Environmental, Health and Safety Conference | Galveston, Texas
February 1, 2013
Speaker | HES Agency Update | E.Vironment Global Issues Forum | Houston, Texas
August 1, 2012
Speaker | Crisis Management: The New Realities | EUCI, Deepwater Oil & Gas: Regulations and Risk Management Conference | Houston, Texas
Ben  Patton


  • JD, Georgetown University Law Center
  • BA, University of California, San Diego, cum laude

Bar Admissions

  • Texas


Legal 500
Legal 500 US - Next Generation Lawyer
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  • Dress for Success Houston, Board of Directors
  • Center for Houston's Future, Business/Civic Leadership Forum, Member