So often the story I read from USEPA and state environmental agency press releases is one of greedy and careless business owners violating the environmental regulations in an attempt to make more money at the cost of the environment and public safety. While I’m sure that image is sometimes correct it is also true that some business owners are simply unaware of the regulations they find themselves in violation of. By the time they are made aware of the violations (let’s say they didn’t properly identify themselves as a hazardous waste generator, properly identify hazardous waste, and train employees on the company’s regulatory requirements), it may be too late. Their awareness comes in the form of an agency inspection and a Notice of Violation.
Now of course we all know that “ignorance of the law is no excuse”, but it is also hard to understand how a company and it’s owners can be punished for the violation of regulations of whose existence they were not aware. That is frequently the case of those who attend my HazMat Employee and RCRA Training Seminars, they simply aren’t aware of the regulations and how they apply to them.
Also, while some actions are so egregious, eg. dumping hazardous waste out back or burning it, some seem relatively harmless and easy to fix without imposing a fine, eg. not labeling hazardous waste drums stored on-site. Yet, in the eyes of the government (state and federal) these are both violations of the regulations subject to fines and penalties.
Not sure of your hazardous waste generator status?
This appears to be the case with a New Haven, CT business owner that finds himself facing the closure of his business due to what seems to be innocent mistakes (Connecticut DEEP fines New Haven business for violations of RCRA regulations). Now, I don’t pretend to know all the facts in this case, and it appears that the business owner may have shot himself in the foot by ceasing to cooperate with the CT DEEP (Read the State of Connecticut’s complaint). Still, the question remains if this is an enforcement action that should have proceeded this far at all. Perhaps a good-faith approach to resolve the issues by both the CT DEEP and the business owner could have protected the environment and saved this small business and its local jobs.
I don’t pretend to know all the facts in this case, but here is what I do know: my high-quality training for Hazardous Waste Personnel could have prevented all of these violations. My training, whether Seminar, Onsite, or Web-Based would have revealed to the business owner the regulations he is alleged to have violated and what he could have done to come into compliance quickly and inexpensively.
An added feature of my Onsite Training is that it includes a free walk-through of your site and a consultation on your regulatory compliance. The information gathered during the walk-through is incorporated into the training materials along with options to attain compliance. Often the fix to the problem, eg. labeling a hazardous waste container , is simple and easy. Whereas the possible violations and fines can be devastating.
Contact me for the training you need, or for a free consultation. I’m happy to answer your questions.
Daniels Training Services