COMPLIANCE INFO_2020 - Laserfiche WebLink

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I statewide information management system is complete, accurate, and in compliance, in violation of 2 Health and Safety Code section 25508.2; 3 d. Failed to complete and/or submit a hazardous materials inventory for all _ w 4 reportable materials on site, in violation of Health and Safety Code section 25506(a); ' 5 e. Failed to complete and/or submit a site map, in violation of Health and Safety 6 Code section 25505(a)(2); 7 f. Failed to submit emergency response plans and procedures for a release or 8 threatened release of a hazardous material, in violation of Health and Safety Code section 9 25505(a)(3); 10 g. Failed to provide training for all new employees and annual training, including 11 refresher courses, for all employees in safety procedures in the event of a release or threatened 12 release of hazardous material, in violation of Health and Safety Code section 25505(a)(4); 13 h. Failed to document training electronically or by hard copy and retain for a 14 minimum of three (3) years, in violation of Health and Safety Code section 25505(a)(4); 15 i. Failed to complete and/or submit a hazardous materials inventory for all 16 reportable materials on site, in violation of Health and Safety Code section 25506(a); and 17 j. Failed to immediately report, upon discovery any release or threatened release 18 of a hazardous material to the unified program agency, in violation of Health and Safety Code 19 section 25510(a). 20 PRAYER 21 WHEREFORE, Plaintiff prays that: 22 1. Defendants be permanently restrained and enjoined from engaging in or performing, 23 directly or indirectly, any and all of the following acts: 24 a. Engaging in any acts in violation of Health and Safety Code section 25100 et 25 seq., including but not limited to: 26 1. Violation of Health and Safety Code section 25189.2(c); 27 2. Violation of California Code of Regulations,title 22 section 28 66262.12(a); -6- VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF