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

Hazardous Waste Enforcement and Compliance Unit Colorado –Population 4,300,000 –8 th 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

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

COMPLIANCE RATE DROPPED

GOAL = COMPLIANCE Enforcement Compliance Assistance –Classroom Training –Generators Assistance Self-Certification

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

NEW FOCUS Compliance ENFORCEMENTINSPECTIONS COMPLIANCE ASSISTANCE

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

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

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.

ENVIRONMENTAL INDICATORS Affects to the Environment Affects to Health and Safety Affects to Environment & Health and Safety

ENVIRONMENTAL INDICATOR TYPE QUESTIONS Affects to the Environment –Transporter –TSD –Illegal disposal

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

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

ENVIRONMENTAL INDICATOR TYPE QUESTIONS Affects to Environment & Health and Safety –Incompatible waste –Hazardous waste training

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

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

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

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?

Future for Autobody Self-Cert Will be annual Add Non notifiers and all Notifiers (CESQGs and SQGs) Will be cross media

Next Sector Dry 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

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

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

Saving the Future