WHY SHOULD I PARTICIPATE?

• Reduced inspection priority

• The ability to correct violations without gravity-based penalties

• Makes you prepared for a random or targeted EPA/DEM regulatory inspection

• Free assistance from DEM and DOH

Reduced Inspection Priority

• Facilities that do not self-certify will be targeted by the Compliance Office in 2004

• OTCA will provide the Department’s Compliance Office with a list of non-participating shops for priority inspections

No Gravity-Based Penalties

• Participation entitles you to protection under the Rhode Island Environmental Compliance Incentive Act

• Allows time to return to compliance

• Protects you from gravity-based penalties and from referral to other governmental authorities

Why is this Important?

• Two case studies of recent violations at Rhode Island auto body shops

Case A - 1999

• Hazardous Waste Management Violations– Greater than 90 day storage– Improper labeling– No weekly inspections of container storage area– No Contingency Plan– Incomplete Training of Employees handling

HW– Incorrect Manifest Forms

Case A - Penalties

• Assessed $54,618.00

• After Settlement Negotiations– $26,150 Gravity Portion– $168.00 Cost Recovery for Testing– SEP worth $6,000.00

Case B - 2002

• Hazardous Waste Management Violations– Greater than 90 day storage, No Secondary

Containment– No weekly inspections of container storage area– No Contingency Plan, No EPA ID #– Incomplete Training of Employees handling

HW– Incorrect Manifest Forms

Case B - Penalties

• Assessed - $30,284.20

• Settlement Negotiations Ongoing

SUMMARY• PARTICIPATE IN THE PROGRAM

• DON’T LET THIS HAPPEN TO YOU!

• RETURN TO COMPLIANCE - BE PREPARED

• ATTEND THE TRAINING SESSIONS