04/27/20 City Council Agenda Packet - Meeting

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Compliance and Auditing As much as possible, the program attempts to proactively encourage compliance. Through proper guidance and education, provided to businesses within the program, coupled with auditing of submitted data the need for more extreme activities from non-compliance has been kept to a minimum. The charter mandated activities, for when a business is non-compliant, have been budgeted at under 1% of program staff time since they are on an as needed basis and rarely needed. 1.Work with businesses in the program to assist them in successfully meeting Charter Amendment hazardous substance reporting requirements and Charter mandated deadline of April 1 st: including providing information and assistance.5 2.Report to the Fire Marshal the names of any hazardous substance users in non-compliance with hazardous materials balance reports requirements.6 3.Publish names of non-complying entities in the daily newspaper.7 4.Investigate evidence of reports not filed in compliance with the Charter Amendment.8 5.Audit the accuracy of hazardous materials balance reports for the Fire Marshal: including follow-up work with businesses to assist them in reconciling errors accurately (site audits are permitted, not required); Conduct site visits of newly-identified businesses as part of Toxics Program representative orientation; Work with Toxics Board to update procedure to implement a more comprehensive audit process, including cross-referencing data reported under other programs.9 6.Work with businesses in the program to assist them in reporting FTE, which the annual fee is based upon; Work with Toxics Board to implement procedure to verify accuracy of number of reported FTE; Perform data entry, print and send invoices to businesses in the program; and Assist businesses in the program meeting the Charter-mandated deadline of st10 May 1 for payment of invoices. 7.Enforce reporting requirements and impose penalties for noncompliance.11 8.Order non-complying repeat offenders to cease and desist using hazardous substances in the City of Eugene.12 9.Members of the Public: Petition the Toxics Board against hazardous substance users or 13 persons for failure to comply with the Charter Amendment. Estimated Compliance & Auditing Total = 25% 5 Article IV, Section 4 6 Article VI, Section 6.2.C 7 Article VI, Section 6.2.D 8 Article VI, Section 6.2.E 9 Article VI, Section 6.2.F 10 Article VII, Section 7.A 11 Article VIII, Section 8.1 12 Article VII Section 8.2.E 13 Article VIII, Section 8.3 4 | Page