Achievable Compliance Goal: Eliminating Notices of Violation Issued to the ArmyUnder the Toxic Substances Control Act

摘要

The total number of notices of violation (NOVs) issued to Army installationspursuant to the Toxic Substances Control Act has been small in comparison to the number of NOVs issued under other Federal regulations. This fact is primarily due to the limited scope of TSCA's direct impact on Army installations. The TSCA provisions regulating the management of polychlorinated biphenyl (PCB) are the ones that most directly affect Army installations; all of the Army's TSCA-based NOVs were issued for PCB-related violations concerning the management of power transformers and capacitors. The Logistics Management Institute investigated 39 NOVs issued to 18 installations under TSCA to determine whether systemic problems existed and whether programmatic changes would be needed to eliminate them. In almost every case, NOVs were received by the Army because of a lack of knowledge about TSCA requirements and/or because of the improper management of PCB material that was given to the local Defense Reutilization and Marketing Office (DRMO) for disposal. Full compliance with TSCA-based regulations can be achieved swiftly and completely. In order to accomplish this, we recommend adequate training programs, a requirement for staff members to complete TSCA training or certification prior to being designated as their installations' responsible individuals, and an integrated waste management system that facilitates coordinated actions between the Army and DRMO. Environment, Compliance, TSCA, NOV, Training.