Chemical Safety’s EMS software can and has been used as part of a company’s Supplemental Environmental Program (SEP), in response to an EPA Notice of Violation (NOV).  From the EPA website, the characteristics of an SEP are:

• There must be a relationship between the underlying violation and the human health or environmental benefits that will result from the SEP.
• An SEP must improve, protect or reduce risks to public health or the environment, although in some cases an SEP may, as a secondary matter, also provide the violator with certain benefits.
• The SEP must be undertaken in settlement of an enforcement action as a project that the violator is not otherwise legally required to perform.

Further information can be found here.  EMS can help correct a multitude of common violations, both directly and indirectly, including:

• Proper labeling of hazardous waste
• Maintaining adequate staff training records
• Maintaining inspection records
• Generating uniform manifests, LDRs and ERGs
• Generating accurate and timely regulatory reports
• Managing time limits (open waste containers, open manifests, permit due-dates, etc.)
• Flagging products/orderds based on regulatory restrictions (TSCA, FIFRA, REACH, etc.)

Having a system in place to avoid violations is preferred, but satisfying the enforcement settlement while improving processes is another intelligent option.  Please contact Chemical Safety for further information.