How COVID-19 Impacted RCRA Hazardous Waste Enforcement
The IG report reviews data collected from California, Georgia, Hawaii, Louisiana, New Jersey, New York, North Carolina, and Texas between March 2020 and February 2021 and compares it to the previous year. Lower RCRA inspection numbers were expected following eleven months of limited travel, remote work for employees, production slowdowns, closures, and staffing changes.
Despite completing far fewer inspections, EPA says that the number of RCRA violations cited per inspection remained relatively steady. EPA says that inspectors observed “approximately one fewer violation for every ten inspections” during this period.
Even in a year when EPA reduced RCRA inspections by almost half, the rate of compliance among hazardous waste generators barely changed.
Why Did RCRA Compliance Stay So Steady?Whether EPA inspects more hazardous waste generator sites in 2022 or fewer, professionals responsible for hazardous waste compliance will continue to identify hazardous waste, count it properly, store it safely, train new hazardous waste personnel, and generally do what it takes to maintain compliance with RCRA.
That’s not because the penalties for noncompliance aren’t expensive. They are. Maximum civil penalties for RCRA violations increase every year and currently sit around $75,000 per day, per violation. Keeping the facility inspection-ready is important, and spotless inspections are certainly a point of pride for EH&S professionals.
But when it comes to why environmental and safety professionals do what they do, day in and day out, monetary penalties are not the primary motivator. One reason RCRA compliance remained so steady in 2020, with or without inspections, is that the individuals responsible for environmental health & safety at facilities nationwide have bigger, more personal reasons to comply with RCRA.
To professionals who are responsible for others’ safety, no job is more important than sending employees home safe at the end of every shift.
Reason 1: To protect people and the environment
Protecting employees from the immediate hazards of hazardous materials and wastes on site is a major reason professionals work tirelessly to accurately identify hazardous waste, provide required RCRA training, properly mark and label containers, inspect storage areas, etc.
Reason 2: To save energy and resourcesConserving the energy and materials we use cultivates a sustainable business strategy while preserving the beauty of nature for years to come. These long-lasting benefits help ensure the water we drink and the air we breathe continue to provide a strong, safe foundation for our facilities and ultimately our communities.
Reason 3: To reduce wasteFacilities that effectively recycle or reuse waste ultimately have less waste to manage, thus reducing the cost of waste transportation, treatment, and disposal. Waste reduction helps facilities run smoothly long-term and reduce the likelihood of a potential accidental release in the future.
Efficient re-use of materials is one area where environmental protection and good business sense go hand-in-hand.
The work of environmental professionals has a profound, multi-generational impact on the environment, our communities, and our families. EH&S leaders are cognizant of what’s at stake when hazardous waste enters the environment and work hard conserve the planet’s natural beauty and protect their communities.
Reason 4: To limit the possibility of future releases and environmental damage
Today, investors and consumers alike focus on environmental, social, and governance (ESG) factors to evaluate organizations, products, and services. Compliance management, environmental stewardship, and limiting environmental liabilities are now key market differentiators across many industries.
These four reasons for good RCRA compliance management align very closely to the “principal objectives” of the Resource Conservation and Recovery Act (RCRA) hazardous waste regulations, which are:
- Protect human health and the environment from potential adverse effects of improper solid and hazardous waste management
- Conserve material and energy resources through waste recycling and recovery; and
- Reduce or eliminate the generation of hazardous waste as expeditiously as possible.
RCRA Training is Key to ComplianceEffective, up to date regulatory training is a core component of a healthy compliance program. US EPA requires annual re-training for personnel at large quantity generator facilities, and personnel at SQG facilities must be “thoroughly familiar” with their responsibilities under RCRA.
The 2022 schedule for Lion’s RCRA Hazardous Waste Management Workshop is now available, and workshops are open for enrollment.
Put Your 2022 RCRA Training on the Calendar Now!
RCRA Hazardous Waste Management Workshop
|Houston, TX||March 2–3|
|Chicago, IL||April 4–5|
|Cincinnati, OH||April 25–26|
|St. Louis, MO||May 2–3|
|Denver, CO||June 6–7|
Sign up now or view the full 2020 schedule:
RCRA Hazardous Waste Management Workshop (2 Days)
This was the 1st instructor that has made the topic actually enjoyable and easy to follow and understand. Far better than the "other" training providers our company has attended!
Process & Resource Administrator
I can take what I learned in this workshop and apply it to everyday work and relate it to my activities.
I like the consistency of Lion workshops. The materials are well put together and instructors are top notch!
Permitting, Compliance & Environmental Manager
Best course instructor I've ever had. Funny, relatable, engaging; made it interesting and challenged us as the professionals we are.
One of the best trainings I have ever received!
Lion is my preferred trainer for hazmat and DOT.
Lion's training was by far the best online RCRA training I've ever taken. It was challenging and the layout was great!
Hazardous Waste Professional
I tried other environmental training providers, but they were all sub-standard compared to Lion. I will not stray from Lion again!
The instructor was great, explaining complex topics in terms that were easily understandable and answering questions clearly and thoroughly.
Much better than my previous class with another company. The Lion instructor made sense, kept me awake and made me laugh!
Enterprise Safety Manager
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