Other Factors That May Have Affected SQG Performance (June 2004 – June 2007)
Colorado is required to announce inspections at least 24 hours in advance. In addition to the advanced warning, they also performed a self certification and had the checklist to go by before we came out. This allowed the facility to prepare for and know what we were looking for on our inspections
Since the inspections were conducted over a 4 year time period, the word got around that we were conducting SQG inspections- this may have had an impact on the level of compliance for the later inspections, but it is difficult to measure if there was any real change in behavior
MA ME NH
ERP Dry Cleaners, Photo Processors, Printers and other targeted groups. Enforcement against “SQGs” that are identified through report reviews to be LQGs.
No information provided
As we have found during ERP projects, few SQGs expect compliance inspections and are sometimes unconcerned about what they consider to be "frivolous" regulations, such as maintaining proper aisle space for drums. NH uses manifest list to generate SQG universe.
Identified a number of SQGs over the past few years when reviewing manifests which had been sent out as CESQGs incorrectly. Follow-up inspections led to the discovery of violations as the facility was not familiar with the regulations. Once the inspection/enforcement cycle ends we hope the performance of these SQGs is improved.
ERP Auto Body, ERP Auto Salvage, Clean Marina Program
SQGs of routinely generated hazardous waste and users of more than 1000 lbs of toxic substances are required to prepare toxics use and hazardous waste reduction plans every three years and annual progress reports
The States Common Measures Project Final Report