COMPLIANCE INFO_2020 - Laserfiche WebLink

Home Browse Search

I FOURTH CAUSE OF ACTION (Violations of Hazardous Materials Release Response Plans and Inventory Laws) 2 (Health & Saf. Code Chapter 6.95 (§ 25500 et seq.); Cal. Code Regs., tit. 19, § 2650 et seq.) 3 49. The People reallege all previous paragraphs. 4 50. Chapter 6.95 of Division 20 of the Health and Safety Code(section 25500 et seq.) 5 require businesses to, among other things, provide training to employees,retain training records, and 6 maintain applicable permits and hazardous materials response plans and inventories. 7 51. Defendant failed to comply with Chapter 6.95 and its implementing regulations set 8 forth ai California Code of Regulations, title 19, section 2650 by, among other things, failing to 9 maintain the required hazardous materials response plans and inventories, training retards, and 10 applicable permits required for the Facilities; and unless enjoined by order of the Court, Defendant I l may or will continue in the course of conduct as alleged in this Complaint. 12 52. Each violation of Health and Safety Code sections 25504 to 25508.2, inclusive, and 13 section 25511, and any applicable permit, rule, regulation, standard, or requirement issued or 14 promulgated pursuant to those sections, discovered within five (5) years of commencing this action, 15 exclusive of any applicable tolling periods and those set forth in paragraph 15 above, subjects 16 Defendant to a separate and additional civil penalty under Health and Safety Code section 25515.2, 17 subdivision(b), or alternatively, under section 25515.2, subdivision (a). 18 53. Based on the above, the People request injunctive relief against Defendant under 19 Health and Safety Code section 25515.6, and civil penalties under Health and Safety Code section 20 25515, as described in the People's prayer for relief. 21 FIFTH CAUSE OF ACTION (Violations of Unfair Competition Law) 22 (Bus. & Prof. Code, § 17200 et seq.) 23 54. The People reallege all previous paragraphs. 24 55. Within four(4) years of the date of commencement of this action, exclusive of any i 25 applicable tolling periods and those set forth in paragraph 15 above, Defendant engaged in, and 26 continues to engage in,unlawful acts, omissions, and practices that constitute unfair competition 27 within the meaning of Business and Professions Code sections 17200 through 17208, as alleged in 28 paragraph 32 and in the First through Fourth Causes of Action; and unless enjoined by order of the - 16- COMPLAINT FOR INJUNCTIVE RELIEF,CIVIL PENALTIES,AND OTHER RELIEF