The regulations enacted under the authority of the Resource Conservation Recovery Act (RCRA) and its many amendments are enforced by both the USEPA and States if they have an authorized hazardous waste program.  In this situation, though its state regulations are enforced by the Maryland Department of the Environment, the USEPA took the lead in imposing fines for the alleged violations of both state and Federal hazardous waste storage regulations.

Please review my summary of the USEPA enforcement action below, or you can read the USEPA press release here:  EPA Settlement with Baltimore Companies Helps Provide Safe Handling of Hazardous Waste

Who:

American Plating Service, Inc. and Monument Street Properties LLC

What:

Companies were cited for violations of RCRA’s hazardous waste storage regulations.  USEPA believes the alleged violations have the potential to result in a release of a hazardous waste that may jeopardize human health or the environment

Where:

Maryland has an authorized Hazardous Waste Program

Baltimore, MD.  A state with an authorized hazardous waste program.

When:

Release date of January 29, 2014

Why:

During two RCRA compliance evaluation inspections of the facility, EPA inspectors observed violations involving hazardous waste stored at the facility, including wastewater treatment sludges from electroplating operations, cyanide-containing spent zinc plating bath solution and ignitable plating bath residues.

The alleged violations included:

• Containers of hazardous waste not properly labeled and dated.
• Hazardous waste containers improperly closed, stored, and/or in poor condition.
• Not providing annual training to Facility Personnel.
• Hazardous waste determinations not completed for all solid wastes generated at the facility.

How Much ($$):

$5,000.  Companies must also conduct an investigation of their facilities to determine the presence and nature of any threat to human health or the environment from an release of hazardous waste.

Lessons Learned:

Well, training is number 1.  If the companies had provided the kind of Hazardous Waste Personnel training that I offer, not only would they have eliminated one of their alleged violations, they would have been informed of the other three (and a lot more) since those are all topics I routinely cover in all of my training formats:  Seminars, Onsite, and Webinars.  The other alleged violations would have been topics of conversation during my Onsite Training which in addition to revealing the potential violation would have given them the knowledge and the tools for compliance.

Hiring someone to conduct Onsite Training at your facility may seem expensive, until you consider fines like these.  Even if you intend to provide your own training, contact me for a free training consultation.