Self-Certification in Colorado Kathryn Stewart and Joyce Williams Colorado Department of Public Health and Environment Hazardous Materials

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

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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

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COMPLIANCE RATEDROPPED
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GOAL COMPLIANCE

• Enforcement
• Compliance Assistance
• Classroom Training
• Generators Assistance
• Self-Certification

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IN THE PAST
Compliance Assistance
Compliance
Enforcement
Routine Inspections
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NEW FOCUS
COMPLIANCE ASSISTANCE
Compliance
ENFORCEMENT
INSPECTIONS
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SCOREVoluntary Self Cert Pilot Study

• SQGs
• Randomly selected
• Questionnaire sent out
• Guidance Documents followed questionnaire with
  explanations
• Emphasis on test compliance
• Lots of good feedback

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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

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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.

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ENVIRONMENTAL INDICATORS

• Affects to the Environment
• Affects to Health and Safety
• Affects to Environment Health and Safety

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ENVIRONMENTAL INDICATOR TYPE QUESTIONS

• Affects to the Environment
• Transporter
• TSD
• Illegal disposal

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ENVIRONMENTAL INDICATOR TYPE QUESTIONS

• Affects to the Environment
• Container management
• Condition
• Open
• Weekly inspections
• Minimize Release

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ENVIRONMENTAL INDICATOR TYPE QUESTIONS

• Affects to Health and Safety
• Emergency Coordinator
• Emergency Postings
• Emergency Equipment
• Arrangements with locals

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ENVIRONMENTAL INDICATOR TYPE QUESTIONS

• Affects to Environment Health and Safety
• Incompatible waste
• Hazardous waste training

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APPLIED LESSONS LEARNED FROM PILOT STUDY

• Mandatory
• Not just SQGs
• Sector specific
• Inspection follow up on 20

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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

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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

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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?

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Future forAutobody Self-Cert

• Will be annual
• Add Non notifiers and all Notifiers (CESQGs and
  SQGs)
• Will be cross media

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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

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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

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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

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self encapsulated
everything is recycled
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Saving the Future