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4.4.2 Observations from Comparing State Activities to Measured SQG Performance Results

After reviewing the performance data, the project states explored the following questions to see if there was a relationship between the data reported and the performance differences among states:

1) Did the Nature and Amount of Regulatory Compliance Assistance Provided Between June 2004 and June 2007 Influence Performance?

CO

Minimal prior to Aug 2007-includes website, guidance documents and quarterly workshops available to all hazardous waste generators. Announced on website only. Generators Assistance Program offers amnesty. Since Aug 2007, required a self cert checklist to be submitted.

CT

On-site assistance during inspections and through handouts, SQG guidance manual and other applicable guidance.

MA

Generic fact sheets on SQG compliance and sector specific workbooks & fact sheets on MassDEP website. Mass Office of Technical Assistance (OTA) provides technical assistance upon request. All SQG enforcement actions are referred to OTA.

ME

Verbal assistance via inspections and telephone; Written compliance assistance via manuals; Written and verbal assistance via seminar or meeting formats; Assistance via Electronic media including web site development and availability of guidance manuals, DEP resources, inspection process, compliance issues, etc.

NH

SQG certification classes, Haz Waste topics training classes, Assistance site visits, assistance of web, RCRA Hot Line.

NY

Technical Assistance at Trade Association Meetings, SQG hotline, SQG compliance guide on web, workshops, P2 assistance guide.

RI

Respond to direct requests for assistance, proactive ERP auto body/auto salvage assistance (includes compliance assistance materials).

VT

Targeted assistance for RCRA-regulated community rather than to SQGs exclusively. Fact sheets and industry sector guides on web. On-line RCRA tutorial, compliance assistance workshops, on-site compliance assistance audits, over the phone assistance.

Regulatory Compliance Assistance Provided to SQG Sector (June 2004 – June 2007)

The States Common Measures Project Final Report

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