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)
Find a Post
The instructor did an excellent job presenting a very dry subject; keeping everyone interested and making it enjoyable.
Hazardous Waste Professional
Excellent. I learned more in two days with Lion than at a 5-day program I took with another provider.
Excellent job. Made what is very dry material interesting. Thoroughly explained all topics in easy-to-understand terms.
I really enjoy your workshops. Thank you for such a great program and all the help Lion has provided me over the years!
Hazardous Material Pharmacy Technician
The instructor's energy, enthusiasm, and knowledge of the subject make the class a great learning experience!
The instructor made the class very enjoyable and catered to the needs of our group.
Best course instructor I've ever had. Funny, relatable, engaging; made it interesting and challenged us as the professionals we are.
Lion is at the top of the industry in compliance training. Course content and structure are updated frequently to make annual re-training enjoyable. I like that Lion has experts that I can contact for 1 year after the training.
Lion Technology workshops are amazing!! You always learn so much, and the instructors are fantastic.
The course was very well structured and covered the material in a clear, concise manner.
Hazmat Shipping Professional
Download Our Latest Whitepaper
Explore ten hazardous waste management errors that caused generators in California the most trouble last year.