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

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

The instructor was very dedicated to providing a quality experience. She did her best to make sure students were really comprehending the information.

Stephanie Venn

Inventory Control Specialist

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

Sarah Baker

Planner

Lion provided an excellent introduction to environmental regulations, making the transition to a new career as an EHS specialist less daunting of a task. Drinking from a fire hose when the flow of water is lessened, is much more enjoyable!

Stephanie Weathers

SHE Specialist

The instructor does a great job at presenting material in an approachable way. I have been able to save my company about $30,000 in the last year with what I have learned from Lion!

Curtis Ahonen

EHS&S Manager

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

I think LION does an excellent job of any training they do. Materials provided are very useful to my day-to-day work activities.

Pamela Embody

EHS Specialist

The training was impressive. I am not a fan of online training but this was put together very well. I would recommend Lion to others.

Donnie James

Quality Manager

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.

Caroline Froning

Plant Chemist

I like the consistency of Lion workshops. The materials are well put together and instructors are top notch!

Kevin Pylka

Permitting, Compliance & Environmental 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.

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.