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

Search for:

Compliance Topics

Compliance Archives

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

Francisco Gallardo

HES Technician

Much better than my previous class with another company. The Lion instructor made sense, kept me awake and made me laugh!

Marti Severs

Enterprise Safety Manager

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

Lion's training was by far the best online RCRA training I've ever taken. It was challenging and the layout was great!

Paul Harbison

Hazardous Waste Professional

Lion Technology workshops are amazing!! You always learn so much, and the instructors are fantastic.

Dorothy Rurak

Environmental Specialist

Our instructor was very dynamic and kept everyone's interest. Hazmat shipping can be a dry, complicated topic but I was engaged the entire time.

Kimberly Arnao

Senior Director of EH&S

We have a very busy work schedule and using Lion enables us to take the course at our own time. It makes it easy for me to schedule my employees' training.

Timothy Mertes

Hazmat Shipping Professional

Lion's information is very thorough and accurate. Presenter was very good.

Melissa Little

Regulatory Manager

My experience with Lion training, both online and in the classroom, is that they are far better organized and provide a better sequential explanation of the material.

Robert Roose

Manager, Dangerous Goods Transportation

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

Sarah Baker

Planner

Download Our Latest Whitepaper

Your hazmat paperwork is the first thing a DOT inspector will ask for during an inspection. From hazmat training records to special permits, make sure your hazmat documents are in order.

Download

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.