Enforcement Actions Under the Resource Conservation and Recovery Act.
Abstract
The Army continues to receive enforcement actions (EAS) that detract from its image as a conscientious adherent to environmental laws In some cases, receipt of violations may indicate the persistent presence of systemic problems In the past 2 years, the Army has been investigating its EAs to determine whether some problems are more prevalent than others and what can be done to resolve them. This report addresses EAs issued to the Army pursuant to the Resource Conservation and Recovery Act (RCRA) and similar state laws and their implementing regulations. RCRA is similar to other regulatory programs reviewed by the Logistics Management Institute, in that the root causes were in procedural and oversight failures. Thus, action taken to address the systemic problems in any of the environmental program areas should relieve compliance problems in all areas. The systemic problems occur in four general areas: maintaining knowledgeable staff; spreading awareness of requirements to operators and supervisors who are not part of the environmental staff; improving oversight of environmentally sensitive operations conducted by both government and contractor personnel; and, once people have the appropriate knowledge, holding them responsible for applying it. We recommend that the Army hold individuals having responsibility for the operation and oversight of environmentally sensitive facilities accountable for proper performance, devise means to make RCRA training more effective, and require certifications and continuing professional development of environmental professionals.
Document Details
- Document Type
- Technical Report
- Publication Date
- Sep 01, 1994
- Accession Number
- ADA292966
Entities
People
- Douglas M. Brown
- Robert J. Baxter
Organizations
- LMI