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Hazardous Waste Enforcement and Compliance Unit

Self-Certification in Colorado Kathryn Stewart and Joyce Williams Colorado Department of Public Health and Environment Hazardous Materials & Waste Management Division 303-692-3361. Hazardous Waste Enforcement and Compliance Unit. Colorado Population 4,300,000

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Hazardous Waste Enforcement and Compliance Unit

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  1. Self-Certification in ColoradoKathryn StewartandJoyce Williams Colorado Department of Public Health and Environment Hazardous Materials & Waste Management Division303-692-3361

  2. Hazardous Waste Enforcement and Compliance Unit • Colorado • Population 4,300,000 • 8th largest state – 104,100 square miles • 5.1 inspector FTE • Generators in the state • 115 LQGs, 850 SQGs, 5,000-10,000 CESQGs • ~300 on-site inspections/year

  3. Hazardous Waste Enforcement and Compliance Unit • Focused on the LQGs 2000-2003 • Increase in compliance rate • Changed focus 2004 • Enforcement follow-up • Manifest reviews • Facilities never inspected • SQGs, small businesses • Complaints

  4. COMPLIANCE RATEDROPPED

  5. GOAL = COMPLIANCE • Enforcement • Compliance Assistance • Classroom Training • Generators Assistance • Self-Certification

  6. IN THE PAST Compliance Assistance Compliance Enforcement $$$$$$$$$$ Routine Inspections

  7. NEW FOCUS COMPLIANCE ASSISTANCE Compliance INSPECTIONS ENFORCEMENT

  8. SQGs Randomly selected Questionnaire sent out Guidance Documents followed questionnaire with explanations Emphasis on test compliance Lots of good feedback SCOREVoluntary Self Cert Pilot Study

  9. AUTOBODY SELF-CERTIFCAITON Mandatory • Define Sector • Set up data base • Create/Mail Questionnaire • Phone call follow up on non-responses • Penalties of $500 and $1000 • Random follow up inspections on 25% of 60 facilities • One potential formal enforcement action

  10. Measurement of Results • We measure results through • Overall compliance • Individual facility compliance • Compare to general population compliance • We identify environmental indicators • Can help us see overall effect • Can help us evaluate where to train better • Apply lessons learned for the next self-cert program.

  11. ENVIRONMENTAL INDICATORS • Affects to the Environment • Affects to Health and Safety • Affects to Environment & Health and Safety

  12. ENVIRONMENTAL INDICATOR TYPE QUESTIONS • Affects to the Environment • Transporter • TSD • Illegal disposal

  13. ENVIRONMENTAL INDICATOR TYPE QUESTIONS • Affects to the Environment • Container management • Condition • Open • Weekly inspections • Minimize Release

  14. ENVIRONMENTAL INDICATOR TYPE QUESTIONS • Affects to Health and Safety • Emergency Coordinator • Emergency Postings • Emergency Equipment • Arrangements with locals

  15. ENVIRONMENTAL INDICATOR TYPE QUESTIONS • Affects to Environment & Health and Safety • Incompatible waste • Hazardous waste training

  16. APPLIED LESSONS LEARNED FROM PILOT STUDY Mandatory Not just SQGs Sector specific Inspection follow up on 20%

  17. Results of Autobody Self-Cert • Very positive feedback • All Questionnaires were returned with no fines • Environmental indicators showed very few issues • Hazardous waste ID misunderstandings

  18. HOW DO WE MEASURE OUR RESULTS? • We measure results within the sector for • Overall compliance with all questions • Individual facility compliance • Compare results of all questions and environmental indicator questions to the self-cert pilot study • Compare results to the general population data

  19. Results of Autobody Self-Cert • Hazardous waste ID misunderstandings • Sent out compliance assistance information letters for distillation bottoms in the trash • Open containers • Weekly inspections • Posting emergency response information • Enforcement not necessary so far?

  20. Future forAutobody Self-Cert • Will be annual • Add Non notifiers and all Notifiers (CESQGs and SQGs) • Will be cross media

  21. Next SectorDry Cleaners Self-Cert • Will be 800 to 1000 participants • Non notifiers and all Notifiers (CESQGs and SQGs) • Trouble Sector • Clean ups on-going for perc plumes • Will be cross media

  22. Dry Cleaners Self-Cert • Up front work with the community • Phone calls • Training • Prepare businesses for the idea of self-certification • Trade Organizations • Small business centers

  23. Summary • Will enhance our ability to achieve compliance through teaching and enforcement • Will eliminate the possibility of not knowing about the regulations • Will help identify deliberate non compliance • Will help businesses who want to be in compliance

  24. self encapsulated everything is recycled

  25. Saving the Future

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