California has unique hazardous waste regulations that include, but substantially exceed requirements of the federal Resource Conservation and Recovery Act (RCRA) regulations generally in effect in other states. It is also hard to navigate California’s hazardous waste requirements because of the dramatic differences in substantive requirements, enforced by pervasive local city and county agencies deputized as Certified Unified Program Agencies
(CUPAs) and result in surprising violations and onerous penalties.
These national and international corporations did not know they were doing anything wrong because, under RCRA, most of these offenses would not be violations, and rarely are the relatively modest offenses so harshly enforced. However, due to widely-varying resources and competence, there are large gaps in compliance assurance, which inevitably leads to intervention by the state DTSC or even U.S. EPA Region 9, usually resulting in substantial penalties.