Search

EPA’s COVID Enforcement Policy Ends 8/31

Posted on 7/16/2020 by Roger Marks

The enforcement discretion policy US EPA implemented in March to help organizations cope with the challenges of the COVID-19 public health emergency now has an end date: August 31, 2020.  

In a memo released in late June, EPA announced that “…it is now appropriate to expressly include a provision in the temporary policy that covers termination of the temporary policy...”

The policy—under which EPA offered some leniency for noncompliance with routine testing, monitoring, sampling, lab analysis, training, and reporting obligations—applies retroactively starting on March 13, 2020.  

Even while the policy remains in place, regulated facilities are expected to make every effort to comply with their environmental compliance obligations. In addition, facilities must report or keep records of any noncompliance with RCRA requirements or other routine obligations to inform EPA’s enforcement decisions.  

Get your annual RCRA hazardous waste training at Lion’s next live RCRA Refresher webinar on July 28.

Policy for Hazardous Waste Generators

Under the temporary COVID-19 enforcement policy, hazardous waste generators who are unable to transfer waste off-site within the required time periods (i.e., 90 or 180 days) can maintain their generator status and not be treated as treatment, storage, and disposal facilities (TSDFs).

Under RCRA, US EPA requires annual training for hazardous waste personnel at large quantity generator facilities. For small quantity generators, training must be provided so that employees are “thoroughly familiar” with the RCRA hazardous waste regulations.

In its policy, EPA states that “many training classes are offered online and such online training generally should not be affected by travel and social distancing constraints.” That said, training is on the list of routine obligations for which enforcement discretion may be applied.

To qualify for enforcement discretion, hazardous waste generators are still required to properly label and store hazardous waste on site.

Start Online RCRA Training Now

Get your annually required RCRA training and keep your expertise up to date! Join a Lion instructor for the RCRA Hazardous Waste Management Refresher Webinar on July 28, August 4, or August 18.

Or train at your own pace with the initial or refresher RCRA online courses. 
RCRA Hazardous Waste Management Online Course
RCRA Hazardous Waste Management Refresher Online Course
 

Tags: coronavirus, COVID-19, EPA, EPA Enforcement, RCRA Training

Find a Post

Compliance Archives

Lion - Quotes

The instructor was excellent. They knew all of the material without having to read from a notepad or computer.

Gary Hartzell

Warehouse Supervisor

Best course instructor I've ever had. Funny, relatable, engaging; made it interesting and challenged us as the professionals we are.

Amanda Schwartz

Environmental Coordinator

The instructor made the class very enjoyable and catered to the needs of our group.

Sarah Baker

Planner

I like Lion's workshops the best because they really dig into the information you need to have when you leave the workshop.

Tom Bush, Jr.

EHS Manager

Excellent. I learned more in two days with Lion than at a 5-day program I took with another provider.

Francisco Gallardo

HES Technician

Excellent class, super instructor, very easy to follow. No rushing through material. Would like to take his class again.

Lawrence Patterson

EH&S Facility Maintenance & Security Manager

The exercises in the DOT hazardous materials management course are especially helpful in evaluating your understanding of course information.

Morgan Bliss

Principal Industrial Hygienist

Lion was very responsive to my initial questions and the website was user friendly.

Michael Britt

Supply Chain Director

The instructor took a rather drab set of topics and brought them to life with realistic real-life examples.

Tom Berndt

HSE Coordinator

The instructor made the class enjoyable. He presented in a very knowledgeable, personable manner. Best class I've ever attended. Will take one again.

John Nekoloff

Environmental Compliance Manager

Download Our Latest Whitepaper

Find out what makes DOT hazmat training mandatory for employees who sign the hazardous waste manifest, a “dually regulated” document for tracking shipments.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.