California Department of Resources Recycling and Recovery (CalRecycle) 

Enforcement Advisory Council Meeting: January 20, 2005

Resolution 2005-01

January 20, 2005

Howard Levenson, Deputy Director
Permitting and Enforcement Division
California Integrated Waste Management Board
1001 I Street
Sacramento, Ca. 95812-4025

Subject: Enforcement Advisory Council Resolution 2005-01; Policy Recommendations Concerning the Draft Training Certification for Landfill Managers and Inspectors Regulations

Dear Mr. Levenson:

The Enforcement Advisory Council (EAC) met on January 20, 2005 and passed Resolution 2005-01, which provides LEA comments and recommendations for Board Members and staff consideration of the draft regulations identified above.

Since the enactment of the 1989 Solid Waste Management Act, EAC members and LEA staff have partnered with the Board to actively support strong technical training as a statutorily mandated component of Enforcement Agency Certification. Through the Board sponsored ‘Partnership 2000’ program, existing technical training became a more robust formal training schedule that has incorporated training by solid waste experts, public and private, and other academic and professional courses. CIWMB staff organized the conduct of comprehensive, technical focused training, at venues throughout the state, in a very cost effective manner.

In consideration of these partnership efforts, the EAC provides the following comments and recommendations:

  • The EAC does not support the current draft regulation package;
  • The EAC is concerned that it may be inappropriate if enforcement agency inspectors are to be certified by, or tested for certification by a registered industry lobbyist organization.
  • The EAC strongly supports continued development of existing Board administered training, and certification programs, and LEA Partnerships, in an efficient and cost effective manner;
  • The EAC supports technical enhanced training in the following: Compost Facilities, Transfer-Processing Facilities, Construction & Demolition Facilities, etc.
  • The EAC supports joint training between EA’s, other Agencies (State and Regional Water Boards, Department of Toxic Substances Control, Air Pollution Control District, etc.), and Operators, Cal-EPA Basic Inspector Academy, and review of the State of Florida, Center for Training, Research, and Environmental Education (UF- TREEO) model of training administration and tracking.
  • The EAC encourages and supports greater focus on state minimum standards, permitting processes, etc.
  • The EAC strongly recommends that the Board make a motion to send this regulation package back to staff with the recommendation to study the expansion of existing Board ‘Policy’ on training and certification, to include the recommendations above.

Should you have any question please contact me at (619) 533-3696 or by email at:
wprinz@sandiego.gov.

Sincerely,

Original signed by

Bill Prinz, Chair
Enforcement Advisory Council

cc: EAC Members
      Ken Stuart, Chair, CCDEH Solid Waste Policy Committee

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Last updated: February 8, 2005
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