So What is a Violation?
I've been putting in some good hours these days... trying to respond to a series of violations my facility received from RCRA. This last year, we changed computer systems on-site and this messed up every compliance program we ever had. As a result, we got alot more violations than we have since the facility opened about 15 years ago.
While I feel somewhat responsible for the violations, I know there is not much I could have done differently to prevent them. Staff was cut, so there was more work to do with less people. Something had to give. The new computer system did not do all the same record-keeping as the old one and without staff or influence over the corporate programmers that control what the new system does, something else had to give. This went on all year with me and my staff complaining up the chain of command how this year was not going to be pretty for violations. And alas, when we got the hefty violation document, they didn't even flinch. Just pay it I think they said. Golly. I'm still struck by that.
So, what do I do? I go through the violations line by line, word by word, picture by picture and try to pick it apart where I can and put a credible defense on the areas I think we are right and they are wrong. There were not alot of those types of violations this year, but there were enough that I think I can justify my existence once again. Maybe knock about 50k off the total fine. That would be nice.
The last few years, I've taken pride in the reduction in number of counts and the corresponding reduction in the dollar figure associated. That is what I do best. I put systems in place and train people and hold them accountable to do their job correctly so we are always operating in compliance with the rules, regulations and permits we possess. That is not always easy, especially with the new hires that have no experience in this industry and don't have to spend time in front of an EPA inspector explaining why something may not be labeled the way they expect or why a document does not appear to them to be filled out correctly as the regulations require. That is always a challenge, but it gets better as those new personnel get experience and realize how much that tiny aspect of their task they are doing on that particular day affects the overall compliance of the facility as a whole.
Well. For the last 2 weeks, I've been acting half like an attorney and half like an engineer trying to explain in a narrative fashion why a particular count is not correct and we are right and they are wrong. Or the opposite, explaining what our corrective actions were on one where they were right and begging forgiveness and groveling in the best narrative form I can.
I think next year will be better, but we have some new permits that the new agency is just now taking a hard look at us for compliance with air rules. We have problems there, and the fines are generally bigger, but I think we've got a better handle around them.
While I feel somewhat responsible for the violations, I know there is not much I could have done differently to prevent them. Staff was cut, so there was more work to do with less people. Something had to give. The new computer system did not do all the same record-keeping as the old one and without staff or influence over the corporate programmers that control what the new system does, something else had to give. This went on all year with me and my staff complaining up the chain of command how this year was not going to be pretty for violations. And alas, when we got the hefty violation document, they didn't even flinch. Just pay it I think they said. Golly. I'm still struck by that.
So, what do I do? I go through the violations line by line, word by word, picture by picture and try to pick it apart where I can and put a credible defense on the areas I think we are right and they are wrong. There were not alot of those types of violations this year, but there were enough that I think I can justify my existence once again. Maybe knock about 50k off the total fine. That would be nice.
The last few years, I've taken pride in the reduction in number of counts and the corresponding reduction in the dollar figure associated. That is what I do best. I put systems in place and train people and hold them accountable to do their job correctly so we are always operating in compliance with the rules, regulations and permits we possess. That is not always easy, especially with the new hires that have no experience in this industry and don't have to spend time in front of an EPA inspector explaining why something may not be labeled the way they expect or why a document does not appear to them to be filled out correctly as the regulations require. That is always a challenge, but it gets better as those new personnel get experience and realize how much that tiny aspect of their task they are doing on that particular day affects the overall compliance of the facility as a whole.
Well. For the last 2 weeks, I've been acting half like an attorney and half like an engineer trying to explain in a narrative fashion why a particular count is not correct and we are right and they are wrong. Or the opposite, explaining what our corrective actions were on one where they were right and begging forgiveness and groveling in the best narrative form I can.
I think next year will be better, but we have some new permits that the new agency is just now taking a hard look at us for compliance with air rules. We have problems there, and the fines are generally bigger, but I think we've got a better handle around them.
posted by Utah Chris at 4:09 PM
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