The MPCA completed 68 enforcement cases in 41 Minnesota counties during just the second quarter of 2014 (April-June).  The civil penalties collected due to these violations exceed $735,000.  The MPCA has 107 environmental enforcement investigations that are ongoing and may yet lead to additional civil penalties.

A complete list of all enforcement actions can be found on the agency’s web site at www.pca.state.mn.us.

The following is a brief summary of all 68 cases completed during the second quarter of 2014:

•  Greenheck Fan Corp., dba Innovent Air Handling Equipment LLC, Minneapolis, for air quality violations, $365,000 (this includes $315,000 toward a supplemental environmental project)
• Industrial Finishing Services, Perham, for air quality violations, $60,000
• Twin Ports Excavating LP, Duluth, for stormwater violations, $53,000 (all to be spent on a supplemental environmental project)
• Two Harbors WWTP, Two Harbors, for water quality violations, $19,000
• La Roche’s, Inc., Faribault, for subsurface sewage treatment systems violations, $14,000
• Gold’n Plum Farms LLC, Sauk Rapids, for air quality violations, $10,000
• Whistling Valley Development WWTP, Lake Elmo, for water quality violations, $10,000
• Norway Beach, Cass Lake, for water quality violations, $8,413
• Schriever Farm LLC, Harmony, for feedlot violations, $6,500
• Vincent & Nancy Hajek property, Glenville, for solid and hazardous waste violations, $6,500
• Stussy Construction, Inc., Mantorville, for stormwater violations, $5,795
• A&F Consulting Group, Winona, for asbestos violations, $5,775
• Sleep Inn Marshall LLC, Marshall, for stormwater violations, $5,700
• Geo’s Paint & Finish LLC, Brainerd, for hazardous waste violations, $5,688
• 528 Partnership LLP, St. Paul, for stormwater violations, $5,600
• Aaron Carlson Corporation, Minneapolis, for hazardous waste violations, $5,500
• Steven Mogard, dba Royal Flush Sanitation S&P, Ortonville, for subsurface sewage treatment systems violations, $5,400
• Hedstrom Lumber Co., Inc., Grand Marais, for air quality violations, $5,050
• Burns Excavating, Inc., Medina, for stormwater violations, $4,850
• Rich Demeules, Medina, for stormwater violations, $4,850
• Albany Recycling Center LLC, Albany, for stormwater violations, $4,700
• Clearwater Paving, Bemidji, for stormwater violations, $4,700
• NuCrane Manufacturing, Hutchinson, for stormwater violations, $4,700
• Consolidated Construction Co., Inc., Marshall, for stormwater violations, $4,300
• Westman Freightliner, Mankato, for stormwater violations, $4,200
• Arrowhead Recycling Center, Two Harbors, for stormwater violations, $4,150
• Castle Danger Demolition Landfill, Two Harbors, for stormwater violations, $4,150
• AW Kuettel and Sons, Inc., Duluth, for stormwater violations, $4,083.75
• Fosston WWTP, Fosston, for water quality violations, $4,019
• Sam’s Well Drilling, Inc., Kevin Sorge property, Austin, for water quality violations, $4,000
• BH Heselton Demolition Landfill, Faribault, for stormwater violations, $3,900
• Cedar Lake Engineering, Inc., Maple Lake, for stormwater violations, $3,900
• Concast, Inc., Zumbrota, for stormwater violations, $3,900
• Innova Industries, Inc., Fergus Falls, for stormwater violations, $3,900
• PaR Nuclear, Shoreview, for stormwater violations, $3,900
• Pepsi Beverages Co., Burnsville, for stormwater violations, $3,900
• Scott Equipment Co., New Prague, for stormwater violations, $3,900
• Silgan Containers Mfg. Corp., Savage, for stormwater violations, $3,900
• Viracon, Inc., Owatonna, for air quality violations, $3,700
• Otter Tail Power Co., Hoot Lake Plant, Fergus Falls, for water quality violations, $3,550
• Gerdau Ameristeel US, Inc., St. Paul, for air quality violations, $3,500
• Prinsco, Inc., Prinsburg, for stormwater violations, $3,400
• L&S Construction, Springfield, for stormwater violations, $3,000
• Zufall Pit, Owatonna, for stormwater violations, $2,854
• Allen & Joey Greibrok, Austin, for asbestos violations, $2,750
• Automotive Concepts, New Hope, for air quality violations, $2,700
• Avon Body Shop, Avon, for air quality violations, $2,500
• Red Wing Cabinetry, Red Wing, for air quality violations, $2,025
• Brad Moe, Chanhassen, for stormwater violations, 1,900
• Cans R Us, Inc., Little Falls, for subsurface sewage treatment system violations, $1,800
• Lake City WWTP, Lake City, for water quality violations, $1,775
• St. Francis Medical Center, Breckenridge, for air quality violations, $1,688
• ISD 676-Badger Public Schools, Badger, for air quality violations, $1,688
• Lundin Construction-NM, Cromwell, for air quality violations, $1,688
• Marcom Service, Inc., New Hope, for air quality violations, $1,688
• Rajala Mill Company, Bigfork, for air quality violations, $1,688
• Spring Prairie Hutterite Colony WWTP, Hawley, for water quality violations, $1,625
• Kaufman Container, Minneapolis, for air quality violations, $1,563
• Eugene Holst, Austin, for water quality violations, $1,500
• Judy Marshal & Susan Kehret, c/o Patricia Woodfill, Brownsdale, for water quality violations, $1,500
• Daniel Weaver, dba Earth Science Soil Testing, North Branch, for subsurface sewage treatment system violations, $1,150
• Vreeman Construction, Raymond, for solid and hazardous waste violations, $1,150
• Gaines Auto Salvage, dba Bridley’s Auto Salvage, Glenville, for stormwater violations, $1,150
• Superior Truck Auto & Marine, Minnesota City, for air quality violations, $810
• Ripley’s Inc., Erhard, for subsurface sewage treatment system violations, $660
• Nick Schmitz, North Branch, for subsurface sewage treatment system violations, $625
• State Bank of Easton, Wells, for asbestos violations, $500
• Judy Machining, Inc., Goodview, for air quality violations, $500

Don’t despair businesses of the Gopher State!  Imposing monetary penalties is only part of the MPCA’s enforcement process.  Agency staff will provide assistance, support, and information on the steps and tools necessary to achieve compliance for any company or local government that requests it.

A complete summary of environmental enforcement actions and news releases can be found on the MPCA’s News Media Center Web page.  For questions on specific enforcement cases, please contact Stephen Mikkelson, Information Officer at (218) 316-3887, or toll free at (800) 657-3864.

The Bullet:

DTSC alleges that FedEx Ground committed more than 1,500 acts resulting in multiple violations of California hazardous waste regulations.  These acts took place at each of FedEx’s thirty-one terminals throughout California.  Alleged violations stem from improper management of broken or leaking packages that contained hazardous materials.  If proven, the violations subject FedEx to civil penalties of up to $25,000/violation.

View the DTSC news release:  DTSC files complaint against FedEx Ground:  Company allegedly mishandled hazardous materials shipped in California

Who:

The Department of Toxic Substances Control (DTSC) is one Department within the California Environmental Protection Agency (Cal EPA).  The DTSC manages the hazardous waste program within the state of California.

FedEx Ground Package System, Inc. (FedEx Ground) is a nationwide Carrier of materials & articles (hazardous & non-hazardous).  In this instance, it is also the Generator of a solid waste.

 What:

Alleged violations include:

• Improper – or absent – hazardous waste determination.
• Unlawful transportation of hazardous waste.
• Transportation of hazardous waste without the Uniform Hazardous Waste Manifest.
• Failure to obtain hazardous waste generator identification numbers.
• Did not send hazardous waste to authorized hazardous waste treatment, storage, and disposal facilities.
• Did not use proper hazardous waste labels and markings on the container.

Where:

Civil complaint filed in Sacramento County.  Violations are alleged to have taken place at FedEx’s thirty-one (31) terminals within California.

When:

News release:  June 26, 2014.

According to the news release, the alleged violations have occurred, “since at least November 2008”.

Why:

The improper management of hazardous waste can lead to the pollution of the environment and jeopardize human health and safety.  DTSC regulates hazardous waste within California to ensure it is managed in a way to minimize its impact on the environment.

How:

As a state with an authorized hazardous waste program, Cal EPA – and DTSC – can create and enforce its own regulations as long as they are at least as strict and broad as those of the USEPA.

Conclusion:

What conclusions can be drawn from this?  Number one, that significant fines and violations can accumulate from a relatively simple lack of awareness of being subject to the regulations.  Pursuant to 40 CFR 262.11 (Federal regulations but adopted by all the states) a generator of any solid waste must determine if it is a hazardous waste.  This is known as the Hazardous Waste Determination.  Simply being aware of this requirement as a starting point could have avoided a significant problem for FedEx Ground in California.

Secondly, despite popular misconceptions, big well-known companies make simple – and costly – mistakes like this all the time.  You as the Generator of a hazardous waste and/or the Shipper of a hazardous material cannot rely on other big-name companies to ensure your compliance.  Their mistakes could cost you!

So what’s the answer?  Training.

If you generate – or even have the potential to generate – any hazardous waste, then someone at your facility must be aware of the applicable regulations of the Resource Conservation and Recovery Act (RCRA).  But more than that, someone must be familiar with the regulations of your state, since, as in this case, the regulations of a state (California) can be much more strict and more broad than those of the USEPA.

I provide that training.  Whether you choose to attend one of my nationwide & year-round Training Seminars, schedule a site-specific Onsite Training, participate in a convenient and inexpensive Webinar Training, or a combination of all three; I’ve can provide you with the training you need to avoid costly fines and penalties.

Please contact me for a free training consultation.

The Bullet:

The generator of a hazardous waste violated basic requirements of the hazardous waste regulations.  And, as a consequence, also violated the Hazardous Material Regulations of the PHMSA/USDOT.  These avoidable violations have resulted in significant criminal violations for this company and its officers.

Who:

Action Manufacturing Company in Atglen, PA.

The initial inspection was conducted by the USEPA’s Land and Chemical Division and the Pennsylvania Department of Environmental Protection (PA DEP).

The case was investigated by the EPA’s Criminal Investigation Division and the U.S. Department of Transportation Office of Inspector General. It is being prosecuted by Assistant U. S. Attorney Elizabeth Abrams.

What:

Action Manufacturing Company’s production process generates an explosive hazardous waste.  State and Federal regulations codified under the Resource Conservation and Recovery Act (RCRA) require hazardous wastes to be managed according to the applicable generator regulations while accumulated on-site and sent off-site for disposal only to permitted hazardous waste Treatment, Storage, & Disposal Facilities (TSDFs).  Instead of complying with these regulations, the company stockpiled hazardous wastes on-site for – in some cases – several years in gross violation of the generator on-site accumulation time limits.

Where:

Action Manufacturing Company is headquartered in Bristol, Bucks County, PA.

The hazardous waste in question was stored at its facility in Atglen, Chester County, PA

When:

Initial inspection was completed by the USEPA’s Land and Chemical Division and the Pennsylvania Department of Environmental Protection (PA DEP) in November 2011.

Action Manufacturing entered the guilty plea on May 21, 2014.

A sentencing hearing is scheduled for August 27, 2014.

Why:

Federal and state hazardous waste regulations require a generator of hazardous waste to comply with applicable regulations in lieu of obtaining a permit for the storage of a hazardous waste.  Indefinite, long-term storage of this type without a permit is not allowed.  Further, evidence of a knowing violation of the regulations can lead to criminal prosecution, as in this case.  Also, as is often the case, violations of the USEPA hazardous waste regulations results in violations of the PHMSA/USDOT regulations for the transportation of a hazardous material (in this case a hazardous waste).

How:

Both Federal and state regulations allow authorities of the USEPA or your state, if it has an authorized hazardous waste program, to enter the property of a hazardous waste generator at any reasonable time and go anyplace hazardous waste are or have been.

Conclusion:

I don’t pretend to know all the facts of this case.  I am relying solely on the news release of the USEPA:  Pennsylvania Company Pleads Guilty to Improper Storage of Explosive Hazardous Waste and Agrees to $1.2 Million Fine.  However, it appears to me that compliance with the regulations of the USEPA and the PA DEP would not have been that difficult and certainly are preferable over this outcome.

Don’t wait!  Contact me for a free consultation regarding your compliance with the regulations of the USEPA, your state, and the PHMSA/USDOT.

The Bullet:

A lot of money ($3.6 million, to be exact) was made available to a variety of organizations to provide training in unspecified environmental disciplines for the unemployed and underemployed in their area.

Who:

United States Environmental Protection Agency (USEPA) made grant money available to 18 grantees nationwide; they are:

• Hunters Point Family; San Francisco, Calif.
• City of Durham, N.C.
• Memphis Bioworks, Tenn.
• City of Milwaukee, Wis.
• Los Angeles Conservation Corps, Calif.
• Cypress Mandela Training Center; Oakland, Calif.
• St. Nicks Alliance; Brooklyn, N.Y.
• Civic Works; Baltimore, Md.
• Community Development Corporation of Tampa, Fla.
• Limitless Vistas; New Orleans, La.
• City of Camden, Ark.
• Energy Coordinating Agency; Philadelphia, Penn.
• Lewis and Clark County, Mont.
• Alaska Forum
• Northstar Center for Human Development; Hartford, Conn.
• City of Detroit, Mich.
• The Workplace, Inc.; Bridgeport, Conn.
• Mo-Kan Regional Council; St. Joseph, Mo.

What:

Grant money to be used to train the unemployed and underemployed on the hazardous waste response (HazWoper) regulations of  the Occupational Health and Safety Administration.

Where:

Nationwide

When:

Announcement made May 12, 2014.

Why:

It is hoped that graduates of the program will go on to private-sector jobs in the “Green Economy”.

How:

Grant money is made available to local/regional organizations that then work with the private sector to provide the training and assist trained individuals with employment.  Read on if you’re interested in Funding Available Through the Workforce Investment Act.

Conclusion:

I’m all for training.  And if grant money is what it takes to get it done, that’s OK too.  Just be sure you get the right training.

Read the USEPA press release.

The Bullet:

Lowe’s stores throughout California were busted by the California DTSC for gross violations of state and Federal hazardous waste regulations.  Lowe’s agreed to pay a settlement of $18.1 million.

Who:

The California Department of Toxic Substances Control (DTSC), DTSC’s Office of Criminal Investigations (OCI), 31 California district attorneys and two city attorneys.  OCI is a special investigation unit within DTSC consisting of peace officers, scientists and a computer forensic specialist who investigate criminal misconduct and other violations of the hazardous waste laws in California. It is the only criminal investigations unit within the California Environmental Protection Agency. It is part of the Office of Legal Affairs.

Lowe’s Home Centers operates more than 1,830 stores in the United States, Canada and Mexico. It serves approximately 15 million customers each week and employs more than 260,000 people.

What:

Under the final judgment, Lowe’s must pay $12.9 million in civil penalties and costs. An additional $2.1 million will fund supplemental environmental projects furthering consumer protection and environmental enforcement in California, and Lowe’s will fund hazardous waste minimization projects of $3.2 million. The retailer will be bound under terms of a permanent injunction prohibiting similar future violations of the law. DTSC will receive about $1.67 million paid as penalties.

Where:

The civil enforcement action was filed in Alameda County, California and led by the district attorneys of Alameda, San Joaquin and Solano counties.  The alleged violations occurred at more than 118 Lowe’s stores throughout California.

When:

The settlement was announced by the CA DTSC on April 2, 2014.  The violations are alleged to have occurred over a six and a half year period.

Why:

It is alleged that more than 118 Lowe’s stores throughout California unlawfully handled and disposed of hazardous wastes. Those hazardous wastes and materials included pesticides, aerosols, paint and colorants, solvents, adhesives, batteries, mercury-containing fluorescent bulbs, electronic waste and other toxic, ignitable and corrosive materials.  At some Lowe’s stores, employees were unlawfully throwing away batteries and compact fluorescent light bulbs that customers had turned in to be recycled.

Stores are required to retain their hazardous waste in segregated, labeled containers to minimize the risk of exposure to employees and customers and to ensure that incompatible wastes do not combine to cause dangerous chemical reactions. Hazardous waste produced by California Lowe’s stores through damage, spills and returns is being collected by hazardous waste haulers registered with DTSC and taken to proper disposal facilities.

How:

From 2011 to 2013, OCI scientists and investigators conducted 17 dumpster examinations to gather evidence. These dumpster examinations revealed that Lowe’s was routinely and systematically sending hazardous wastes into local landfills throughout California that were not permitted to receive those wastes.

For More Information:

Contact: Russ Edmondson
(916) 323-3372
russ.edmondson@dtsc.ca.gov
Contact: Tamma Adamek
(916) 324-2997
tamma.adamek@dtsc.ca.gov

FOR GENERAL INQUIRIES: Contact the Department of Toxic Substances Control by phone at (800) 728-6942 or visit www.dtsc.ca.gov. To report illegal handling, discharge, or disposal of hazardous waste, call the Waste Alert Hotline at (800) 698-6942.

Read the DTSC press release:  Lowe’s to Pay $18.1 Million Settlement for Illegal Handling and Disposal of Hazardous Waste

Conclusion:

Lowe’s, like others in the retail industry, face unique challenges in the management and disposal of the hazardous waste they generate.  That’s why the USEPA is currently seeking comments from those within the retail industry regarding the drafting of regulations specific to them.  These violations are a good example of what can happen at a retail store – or any business – when facility personnel do not receive the required training:  Hazardous Waste Personnel and HazMat Employee and as a result lack even a basic understanding of what is required for compliance.

Please don’t hesitate to contact me with any questions about the hazardous waste regulations of the USEPA, CA DTSC, or whatever state your business is located.

The Bullet:

Federal Cartridge Company has been fined and required to take corrective actions as a result of hazardous waste violations at its ammunition manufacturing facility in Anoka, MN.

Read the press release:  Federal Cartridge Company in Anoka penalized for hazardous waste violations

Contact:  Stephen Mikkelson of MPCA at (218) 316-3887 for more information.

Who:

• Federal Cartridge Company
• Minnesota Pollution Control Agency (MPCA)

What:

Federal Cartridge Company has been assessed a fine of $44,500 for the following violations of MPCA regulations:

• Failure to clean up a discharge of wastewater containing lead.  The leachable concentration of lead in the discharge was determined to be greater than the regulatory threshold of 5.0 mg/L and therefore a hazardous waste for the Toxicity Characteristic of Lead.  By not promptly cleaning-up the discharge of wastewater it becomes on-site disposal of hazardous waste to land without a permit.
• Failure to gain prior approval from MPCA or to modify its hazardous waste facility permit for construction of a waste treatment tank.  Since the press release refers to a “waste treatment tank” and not a wastewater treatment tank, I assume that Federal Cartridge Company treats its own hazardous waste on-site to reduce it’s volume, make it non-hazardous, or make it easier or cheaper to dispose of.  Further, reference is made to the company’s “hazardous waste facility permit”.  Treatment of wastewater is regulated under the Clean Water Act (CWA) whereas treatment of waste is regulated under the Resource Conservation and Recovery Act (RCRA).

Where:

Federal Cartridge Company is located in Anoka, MN

When:

• Initial inspection by MPCA conducted May 2013.
• Construction project (without MPCA approval) initiated later in 2013.
• Penalty announced by the MPCA March 19, 2014.

Why:

The actions of Federal Cartridge Company are viewed by MPCA to be a threat to the health and safety of the people and environment of Minnesota and therefore require correction and a penalty.

How:

As a state with an authorized hazardous waste program under RCRA, the MPCA is responsible for the enforcement of hazardous waste regulations in Minnesota.  A state may make its own regulations more strict and more broad than those of the USEPA, which MPCA has done.  MPCA may enter a facility at any reasonable time to conduct an inspection of its property, collect samples for analysis, and review company records.

Conclusion:

Two important take-aways from this incident:

1. A spill or release that is not promptly cleaned-up may be identified as disposal by a regulatory agency.  If the spill or residue is a hazardous waste, then watch out!
2. No action should be taken at an industrial facility (and not just industrial, take a look at the $81 MILLION fine paid by WalMart) without considering the impact on environmental regulatory compliance, state and Federal.

The Bullet:

Dlubak Glass, based in Blairsville, PA will pay a fine of $120,000 to the Arizona Department of Environmental Quality for violations of the Resource Conservation and Recovery Act (RCRA) regulations.

Read the ADEQ press release:  Arizona DEQ fines glass recycler

 Who:

Dlubak Glass, based in Blairsville, PA operates a cathode ray tube recycling facility in Yuma, AZ.  Violations were found and civil penalty assessed by the Arizona Department of Environmental Quality.

What:

“During an inspection ADEQ inspectors found broken CRT glass throughout the five-acre facility and stained soil in several locations. The stained soil also was observed extending about 20 feet into an orchard adjoining the Dlubak property. Samples taken on the property found levels of lead as much as 75 times more than the maximum federal and state exceedance level of five milligrams per liter.

In addition, the broken glass was stored in open, unlabeled cardboard containers and washing activities were conducted on an outdoor concrete pad. State regulations require that all CRT storage and processing activities be conducted within a building with a roof, floor and walls.”

Dlubak Glass was assessed a penalty of $120,000 for the above violations.

Where:

The Dlubak Glass facility where the violations occurred is located at 19538 S. Avenue 1 East in Yuma, AZ.  Dlubak Glass has other plants located in Pennsylvania, Ohio, Kentucky,Texas, and Oklahoma.

When:

Date of initial inspection was not indicated in the ADEQ press release.  The date the decision was announced was March 7, 2014.

Why:

“Their unlawful management of hazardous waste put employees and the environment at risk,” said ADEQ Director Henry Darwin. “But they hired environmental consultants, changed their operating procedures and did the soil cleanup in reaching a resolution in the case.”

Cathode ray tubes are found in many older computer monitors and televisions.  If recycled properly they are excluded from the definition of a solid waste and are therefore subject to little or no regulation.  However, the exclusion hinges on proper recycling of the CRTs which was not the case here.  If improperly managed during recycling CRTs may release lead and other harmful pollutants into the environment.

How:

As a state with an authorized hazardous waste program, the Arizona DEQ has the authority to inspect, investigate, and assess fines of facility’s found to be in violation of state regulations.  The state regulations of the ADEQ are designed to protect the health and safety of the environment and people of Arizona.

Conclusion:

The Bullet:

A county landfill has paid a civil penalty of $12k for its illegal acceptance of liquid hazardous waste.  View the release from the MPCA:  Crow Wing County Landfill penalized for hazardous and solid waste violations

Who:

Crow Wing County Landfill and the Minnesota Pollution Control Agency (MPCA).  Contact:  Stephen Mikkelson, (218) 316-3887

What:

The facility accepted for temporary storage 15 barrels labeled as a characteristic hazardous waste (D001 for Ignitability). The barrels were disposed of in the municipal solid waste portion of the landfill.

Where:

Crow Wing County Landfill is located east of Brainerd, MN

When:

Violation occurred November of 2012.

Announced March 5, 2014

Why:

A hazardous waste (D001 for Ignitability) must be treated, stored, or disposed of only at a facility that has a permit under Subtitle C of the Resource Conservation and Recovery Act (RCRA).  Such a facility would also have to operate in compliance with the USEPA regulations of 40 CFR 264/265 (or their State equivalent).  A municipal solid waste landfill cannot accept hazardous waste for disposal unless there is an exception allowed by the state for hazardous waste from a Conditionally Exempt Small Quantity Generator (CESQG).  Given the quantity of hazardous waste in this case, it is unlikely it originated from a CESQG.  Also, liquids of all kinds (hazardous or non-hazardous) are banned from landfill disposal.

How:

As a state with an authorized hazardous waste program, the MPCA has the authority to enforce hazardous waste regulations within Minnesota.

Please don’t hesitate to contact me if you have any questions about the management of hazardous waste or the transportation of hazardous materials.

Even those states without authorized hazardous waste programs under RCRA (Iowa, Alaska, & Puerto Rico) are responsible for the management of non-hazardous solid waste within their state.  While regulations for hazardous waste find their authority in Subtitle C of the Resource Conservation and Recovery Act, non-hazardous wastes are addressed in Subtitle D of RCRA.  It’s in Subtitle D that the USEPA delegates the management of non-hazardous waste to each state.  I have found that the states take a myriad of approaches to the management of non-hazardous waste and in this article we will read of how Massachusetts is enforcing its ban from landfill disposal for certain recyclable materials. (more…)

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 (more…)