1. Self-Certification in Colorado Kathryn Stewart and Joyce Williams Colorado Department of Public Health and Environment Hazardous Materials & Waste Management Division 303-692-3361

2. 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

3. 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

4. COMPLIANCE RATE DROPPED

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

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

8. NEW FOCUS Compliance ENFORCEMENTINSPECTIONS COMPLIANCE ASSISTANCE

9. 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

10. 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

11. 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.

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

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

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

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

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

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

18. 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

19. 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

29. 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?

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

31. 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

32. 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

33. 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

35. Saving the Future