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Silvertree
February 1st, 2010, 11:25 AM
How Is My Compliance Determined, and What Happens if the
Agency Discovers a Violation?

To maximize compliance, EPA implements a balanced program of compliance assistance, compliance incen*
tives, and traditional law enforcement.

EPA knows that small businesses that must comply with complicated
new statutes or rules often want to do the right thing, but may lack the requisite knowledge, resources, or
skills. Compliance assistance information and technical advice helps small businesses to understand and
meet their environmental obligations.

Compliance incentives, such as EPA’s Small Business Policy, apply to
businesses with 100 or fewer employees and encourage persons to voluntarily discover, disclose, and cor*
rect violations before they are identified by the government (more information about EPA’s Small Business
Policy is available at www.epa.gov/compliance/incentives/smallbusiness/index.html). EPA’s enforcement program is aimed at protecting the public by targeting persons or entities who neither comply nor cooperate to address their legal obligations.


EPA uses a variety of methods to determine whether businesses are complying, including inspecting work
sites, reviewing records and reports, and responding to citizen tips and complaints. Under TSCA, EPA (or a state, if this program has been delegated to it) may file an enforcement action against violators seeking
penalties of up to $32,500 per violation, per day. The proposed penalty in a given case will depend on many factors, including the number, length, and severity of the violations, the economic benefit obtained by the violator, and its ability to pay. EPA has policies in place to ensure penalties are calculated fairly.

These policies are available to the public. In addition, any company charged with a violation has the right to contest EPA’s allegations and proposed penalty before an impartial judge or jury.
EPA encourages small businesses to work with the Agency to discover, disclose, and correct violations.

The Agency has developed self-disclosure, small business, and small community policies to modify penal*
ties for small and large entities that cooperate with EPA to address compliance problems. In addition, EPA
has established compliance assistance centers to serve over one million small businesses (see Construction
Industry Compliance Assistance Center for information regarding this rule at www.cicacenter.org). For more information on compliance assistance and other EPA programs for small businesses, please contact EPA’s
Small Business Ombudsman at 202-566-2075.

Allrounder
February 1st, 2010, 01:17 PM
So in other words, you may or may not get caught, because they may or may not enforce it. And if you do get caught, you may or may not get penalized, depending on what the EPA determines is fair.

Thanks, that really clears things up. :rolleyes3:

Bodger
February 1st, 2010, 02:01 PM
They'll pop whoever they can and make examples out of them, and probably put some good men and women out of business in the process.

It's like OSHA. If they come to your site, they WILL find a violation. Whether or not it's a catastrophic fine is up to them. I don't think it's possible to run an active job site and be in compliance with OSHA regs 100% of the time. This lead paint thing will probably the same.
It's like gun laws in CA. The challenge is to find out what IS and ISN'T legal, then comply if you can, and hope like hell law enforcement officers you may deal with know the laws as well.
And if they don't, even if you're legal, you'll take a big hit proving it after the fact.

Silvertree
February 1st, 2010, 02:19 PM
Gee Allrounder, I think I detect some sarcasm in your post:rolleyes3:

WarnerConstInc.
February 1st, 2010, 05:22 PM
I'm going to kick them in the junk and run!!

Bodger
February 1st, 2010, 05:24 PM
We need one of those Men In Black "Flashy Things" to use on these EPA types,

rselectric1
February 1st, 2010, 05:43 PM
We need one of those Men In Black "Flashy Things" to use on these EPA types,

What types of vehicles to EPA personnel drive? I'm guessing it's either a gas guzzling crown vic or suburban. (Oh wait..)

paulie
February 1st, 2010, 06:33 PM
Sounds like a lot has to be sorted out yet at the EPA.

Bodger
February 1st, 2010, 07:04 PM
While they are sorting, I wonder how many contractors take a bust. It's got to happen pretty soon after the law takes effect. I'm sure we'll read about it.

PA Woodbutcher
February 1st, 2010, 07:15 PM
While they are sorting, I wonder how many contractors take a bust. It's got to happen pretty soon after the law takes effect. I'm sure we'll read about it.

The government is always looking for new sources of revenue.:rolleyes3:

Bender
February 1st, 2010, 08:34 PM
What types of vehicles to EPA personnel drive? I'm guessing it's either a gas guzzling crown vic or suburban. (Oh wait..)

Leaded, or unleaded?;)