California Department of Resources Recycling and Recovery (CalRecycle) 

Enforcement Advisory Council Meeting: April 19, 2006

Resolution 2006-04

July 10, 2006

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 2006-04; Formation of a Task Force to Consider and Make Recommendations Regarding LEA Document Retention

Dear Mr. Levenson:

At the April 19, 2006 EAC meeting, Resolution 2006-04 was passed to form a task force to review the types of records LEA’s maintain for different types of facilities and to make recommendations regarding which records need to be saved; length of time different documents need to be kept; and the manner in which records may be stored. The resolution also requests CIWMB staff be authorized to participate on the task force. Ultimately, task force conclusions and recommendations will be forwarded through appropriate channels for Board consideration.

Title 14 California Code of Regulations (14 CCR), Section 18020(a) states, “Every enforcement agency shall maintain a file on each disposal site and facility within its jurisdiction.” 14 CCR 18020(d) further requires, “All files and their contents shall be retained by the enforcement agency for as long as a facility or disposal site physically exists, and until written discard approval is given by the Board.” Furthermore, statute, such as 30 PRC 43101(c)(2), clearly separates agency roles, in this case the state/regional water boards and CIWMB/LEA’s.

The maintenance of the required files consumes a great deal of storage space, which for many LEA’s is limited. Technological advances can provided options for document storage but should not be implemented in a haphazard manner. It is the goal of the EAC to find a reasonable approach to file maintenance that also serves the need to keep documents that may be necessary in the future.

Should you have any questions, please contact me at (619) 533-3696 or by e-mail at:


Original signed by

William E. Prinz, Chair
Enforcement Advisory Council

cc: EAC Members
      Ben Gale, Chair, CCDEH Solid Waste Policy Committee

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Last updated: July 28, 2006
Enforcement Advisory Council (EAC)
Leta Forland: (916) 341-6395