When thinking of those subject to state and Federal regulations for the management of hazardous waste, it’s natural to think manufacturing and industry.  However, when the Resource Conservation and Recovery Act (RCRA) was drafted the intent was to regulate the generation, management, treatment, transportation, and disposal of hazardous waste from Cradle-to-Grave no matter the source.  This means that businesses very different from what we think of as heavy industry or manufacturing are subject to RCRA regulations and can be subject to penalties, fines, and violations for non-compliance.  A perfect example of this is the retail sector which has had a few high-profile compliance issues recently:

• Lowe’s in California agrees to $18.1 million settlement for hazardous waste violations.
• Guilty plea and $81 million fine for Wal-Mart.

As an example of the cost of non-compliance for the retail industry in just one state, see the table below for data collected by the California EPA’s Department of Toxic Substances Control for monetary settlements received just since 2010.

The hazardous waste regulations in California are more strict & more broad than those of the USEPA.

Have you trained your Facility Personnel on the RCRA Hazardous Waste regulations?

Of course, training – both HazMat Employee and Hazardous Waste Personnel – can prevent the violations that lead to these monetary settlements.  Another potential source of relief is the request for comments from the USEPA regarding the creation of hazardous waste regulations specific to the Retail Sector.  Now is the time for your voice to be heard!  But hurry, the deadline for comments is April 15th.

There is no deadline for training, so contact me with any questions you have about the regulations of the USEPA & the USDOT and the specific requirements of your state.