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How COVID-19 Impacted RCRA Hazardous Waste Enforcement

Posted on 12/20/2021 by Roseanne Bottone and Lauren Scott

EPA performed 47% fewer inspections of hazardous waste generator facilities during the COVID-19 public health emergency, according to a report released by the agency’s Inspector General (IG) on December 1.

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. 


Reason 1: To protect people and the environment

To professionals who are responsible for others’ safety, no job is more important than sending employees home safe at the end of every shift.
 
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 resources

Conserving 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 waste

Facilities 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.


Reason 4: To limit the possibility of future releases and environmental damage

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.
 
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.
Some folks speed on the freeway and roll through stop signs unless there’s a police car nearby. When it comes to the work that environmental professionals do every day—that’s just not how they operate. 

RCRA Training is Key to Compliance

Effective, 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) 

Tags: environmental compliance, hazardous waste management, RCRA

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