What should be done after a second incident of a Substantive Actual violation?

After a second incident of a Substantive Actual violation, it is essential to reaffirm compliance actions while introducing new measures. This approach ensures that the organization addresses the underlying issues that contributed to the violations, promoting a proactive rather than a punitive response. By reinforcing compliance, the organization demonstrates a commitment to adhering to regulations and improving operational standards to prevent future violations.

Implementing new measures can include enhanced training for personnel, revising operational procedures, or introducing stricter monitoring systems. This not only aims to rectify the immediate concerns that led to the violations but also fosters a culture of accountability and continuous improvement, which is critical in maintaining environmental integrity and compliance. This strategy acknowledges the seriousness of repeated violations while focusing on corrective actions that can lead to sustainable compliance.

Choosing a path that involves termination of services or law enforcement referral may be warranted in extreme cases or future incidents, but after a second violation, an emphasis on corrective compliance actions is generally considered the most constructive path forward. The idea is to learn from past mistakes and enhance the overall framework for managing compliance issues, thus reducing the risk of recurrence.