Maintenance Facilities - Technical Advocacy in Support of Response to CUPA Enforcement Action
A routine inspection by the local certified unified program agency (CUPA) resulted in a Notice of violation that was issued to a mid-sized commercial business with multiple facilities located throughout California. While the NOV addressed violations of California hazardous waste regulations at single site, outside environmental legal counsel was concerned that potential non-compliance may be present at their client’s other locations as well. Further, the NOV specified a compressed schedule within which noted violations were to be corrected, after which certifications of compliance were required to be submitted to the agency. ALG was contracted to confirm and correct all the issues noted in the NOV, and concurrently, to assess and if necessary, correct potential hazardous waste compliance issues at the client’s other facilities throughout California.
ALG applied a systematic approach to verify all aspects of compliance with California hazardous waste control requirements among all the client’s California operations. ALG prioritized those issues identified in the Notice of Violation, and developed compliance strategies that could be implemented within the compressed period provided for by the NOV. In addition, ALG assessed programmatic compliance issues though multiple site inspections. Leveraging our practical experience in hazardous waste management, the ALG team implemented simple, practical waste accumulation and management systems among all the sites, which included on-the-job training as well as live webinars to share lessons learned among all site staff. Working with legal counsel, ALG developed technical advocacy including strategies to minimize civil penalties and expedite compliance and document the successful implementation of the new programs.
Working with our client and legal counsel, ALG designed, implemented, and secured full compliance with California hazardous waste requirements across all our client’s California operations. In addition to fully addressing compliance issues identified in the NOV, ALG implanted corrective actions, which was supported by full compliance training and follow-up audits. As this work was completed within a compressed period of the NOV, the CUPA allowed our consultation services to be counted towards the supplemental environmental project (SEP) as they exceeded the CUPA’s expectation. This not only reduced our client’s overall compliance costs, but also provided a solid foundation for further interaction with CUPA staff.