No matter how many times I read about it, I never fail to be surprised by two things:

1. The severity of penalties faced by regulated facilities that violate US EPA hazardous waste (RCRA) regulations; and,
2. How easily avoidable those violations are.

Examples:

For hazardous waste violations noted by the Arizona Department of Environmental Quality, Metco Metal Finishing, Inc. in South Phoenix, AZ must pay a $75,000 penalty, spend $50,000 for a yet to be determined supplemental environmental project, institute an environmental management system, and contract with a third party to conduct regular audits at its facility for the next three years.  Its 26 violations include disposal of hazardous waste without a permit, failing to properly mark containers, and failing to determine if some stored materials were hazardous waste.

US EPA fined TMW Corporation in Van Nuys, CA $100,000 for its RCRA violations which included:

• Storage of hazardous waste for over 90 days without a permit.
• Failure to conduct required inspections.
• Failure to train personnel or maintain training records.
• Failure to maintain required emergency communications equipment.
• Failure to make a hazardous waste determination.

The Robert J. Dole Veterans Administration Medical Center in Wichita, KS was fined $17,979 by US EPA for hazardous waste violations on its campus.  The Veterans Administration must also spend an estimated $61,900 on a supplemental environmental project to erect a hazardous waste accumulation building on-site.  The violations of the federal Resource Conservation and Recovery Act (RCRA) and Kansas Administrative Regulations noted during the inspection included failures to make hazardous waste determinations, failures to inspect, label, date and close hazardous waste containers; failures to make arrangements with emergency responders, failures to label used oil containers, and disposal of hazardous waste through the biological waste system.  As part of the settlement, all facets of the facility’s hazardous waste management will be closely scrutinized by the US EPA.

All of the above violations are simple to avoid.  However, a facility cannot comply with a regulation that it is not aware of.  Awareness can begin with a training session that meets your regulatory requirements for training hazardous waste personnel and HazMat Employees and  explains in detail what you need to do to maintain compliance at your facility.  Your facility’s EHS Manager and your Shipping and Receiving Manager would benefit greatly from attending one of my nationwide public training events.  Or, even better, have me come to your site to provide on-site training to all of your applicable employees (Hazardous Waste Personnel and HazMat Employees) for one flat fee of $1,749.