ISO 14001 Registered and out of Compliance - What should happen?

[tarheels4 - 2007]

What should a registrar do if a company has a significant violation of hazardous waste regulations (RCRA) in multiple cases? I am not sure if this site is registered but the parent company, Canadian General-Tower is ISO 14001. Not sure if this is a multi-site registration and covers the Toledo facility. Also does any one know if this particular location in Toledo is registered to ISO 14001? Just curious.

Certainly an organization can remain registered while out of compliance, but the multiple violations and fines would be pushing the limits on maintaining registration, not to mention a possible public relations nightmare for the registrar.

http://www.toledoblade.com/apps/pbc...60321/NEWS16/60321009&SearchID=73239232669047
Textileather will pay $18,000 Ohio EPA fine

Back in 2000 they were fined for RCRA violations as well. http://www.epa.state.oh.us/pic/nr/2000/october/textilea.html

Complaince info on facility. Has not been updated with recent information in the Blade above.
http://www.epa.gov/cgi-bin/get1cReport.cgi?tool=echo&IDNumber=110000384094

Holy Toledo!

 

[RoxaneB]

I have heard of companies losing their registration for being out of compliance with regulations. The reasons can stated along the lines of lack of commitment to their own policy (especially if they have been out of compliance for a long period of time), management committment, environmental aspects (items that are under its control obviously are not and efforts are not being taken to regain control), evaluation of compliance, nonconformance/corrective action...and all the ties in between. Basically, if out of compliance and no actions exist to regain compliance, you're looking at a breakdown of the system. I'd say this is a major, at a minimum...but, as I said at the beginning, I've heard of companies losing their registration over stuff like this.

 

[BadgerMan]

Basically, if out of compliance and no actions exist to regain compliance, you're looking at a breakdown of the system. I'd say this is a major, at a minimum...but, as I said at the beginning, I've heard of companies losing their registration over stuff like this.

Says a bunch about the effectiveness of their corrective action system and level of management commitment, if nothing else.

 

[tarheels4 - 2007]

Says a bunch about the effectiveness of their corrective action system and level of management commitment, if nothing else.

I would say that based on the public record, the organization has a relatively weak corrective and preventative action system.

 

[ralphsulser]

Hey, I was involved in the final inventory for Textile Leather when General Tire(aka GenCorp) sold it to the employees in '89. It was considered a reclamation problem long before that.

 

[Randy]

Good question............Remember, Registrars and ISO 14001 registration do not guarantee compliance. Every registrar has requirements and the accreditation bodies for registrars have requirements concerning "compliance".

Essentially, if the organization has identified a non-compliant situation, developed and initiated the CA/PA process and taken all the necessary steps the cert shouldn't be at risk under normal conditions. An NOV with associated fines can be a product of the organization actually fulfilling its compliance requirements from a "self reporting" activity from deviating from a permitted condition. They can get fined for complying with the law. Those of us that have actually tread the compliance pathway managing permitted operations understand that.

Now if an organization has not recognized a non-compliance, or has not initiated corrective action, or has failed because of lack of committment or for a variety of other reasons, then there may be potential for a certificate to be withdrawn.

Everything is case by case even in the event of multiple occurances.

 

[tarheels4 - 2007]

Hey, I was involved in the final inventory for Textile Leather when General Tire(aka GenCorp) sold it to the employees in '89. It was considered a reclamation problem long before that.

Yea, Gencorp. Wasn't that a Superfund site with lots of PCBs?

 

[tarheels4 - 2007]

Everything is case by case even in the event of multiple occurances.

I would think that this would be a no brainer for the registrar, if only to protect its' good name and business. I wonder what its' name is?

 

[Randy]

A violation does not necessarily mean the organization has caused harm to the environment. An NOV can be issued for an administrative oversight or error; failure to place a date on a hazardous waste label, missing an opacity check, having a loose bung on a drum, missing a report date by one day and a million other things.

I got about a dozen CalEPA/RCRA NOV's in one day from an over eager dipstick "intern" who hammered me because waste labels were not visible from where she was standing. A very critical and serious legal violation!!

 

[tarheels4 - 2007]

A violation does not necessarily mean the organization has caused harm to the environment. An NOV can be issued for an administrative oversight or error; failure to place a date on a hazardous waste label, missing an opacity check, having a loose bung on a drum, missing a report date by one day and a million other things.

I got about a dozen CalEPA/RCRA NOV's in one day from an over eager dipstick "intern" who hammered me because waste labels were not visible from where she was standing. A very critical and serious legal violation!!

Normally fines like these are only for repeat or gross violations, IMO. Repeat violations in the same area reveal a lack of commitment to compliance. A company can't maintain a registration without a commitment to compliance.