By this Order I find Heritage-Crystal Clean, LLC committed two (2) violations of the Hazardous Materials Regulations (HMR), 49 C.F.R. Parts 171-180. Accordingly, I assess Respondent a $4,680 civil penalty for the violations.
I. Summary
Respondent: Heritage-Crystal Clean, LLC
950 Northland Boulevard
Cincinnati, OH 45240
ATTN: Ms. Catherine McCord, Vice President
No. of Violations: 2
Total Payment Due: $4,680
II. Finding
This matter comes before me after Respondent and the Pipeline and Hazardous Materials Safety Administration (PHMSA) agreed to a disposition of this case. I find Respondent committed the violations described in the Compromise Agreement (Agreement), which I have attached hereto. I have reviewed the Agreement and I find that the terms as outlined therein are in the best interest of justice. The Agreement, in its entirety, is incorporated in and attached to this Order. All of the terms and conditions of the Agreement shall be given the full force and effect of an Order issued pursuant to the Federal hazardous materials transportation law, 49 U.S.C. § 5101, et seq., or the Hazardous Materials Regulations, 49 C.P.R. Parts 171- 180.
A situation like this reinforces a point I made in an earlier article, Do Big Companies Know the Regulations? That is, that big companies, even those with names you recognize, frequently violate the Hazardous Material Regulations of the USDOT/PHMSA through ignorance of the regulation. So don’t rely on a “Big Company” when your compliance with the regulations are at stake. Make certain you have the training and the knowledge necessary to ensure compliance with the regulations. Please contact me with any questions.