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I I I quantity, and the health risks of hazardous materials handled, used, stored, or disposed of in the state, 2 which could be accidentally released into the environment, be made available to firefighters, health 3 11 officials, planners, public safety officers, health care providers, regulatory agencies, and other 4 interested persons. R ENFORCEMENT AUTHORITY 6 1 18. Business and Professions Code section 17206 imposes civil liability for any act of 7 unfair competition, as defined in Business and Professions Code section 17200. 8 19. Section 25189 of the Health and Safety Code imposes civil liability for any negligent 9 or intentional violation of the HWCL and 'Jur any violation of any permit, rule, regulation, standard, 10 or requirement issued or promulgated pursuant to the HWCL. Section 25189.2 of the Health and I 1 Safety Code is an alternative strict -liability provision that creates liability for any violation of the 12 HWCL and for any violation of any permit, rule, regulation, standard, or requirement issued or 13 promulgated pursuant to the HWCL. 14 20. Section 25515, subdivision (b), of the Health and Safety Code imposes civil liability 15 for any knowing violation of Sections 25504 to 25508.2, inclusive, or Section 25511, of the Health 16 and Safety Code. Section 25515, subdivision (a), of the Health and Safety Code is an alternative 17 strict -liability provision that imposes civil liability for any violation of Sections 25504 to 25508.2, 18 inclusive, or Section 25511, of the Health and Safety Code. 19 21. Business and Professions Code section 17203 authorizes the Court to issue an order 20 that enjoins any person who engages, has engaged, or proposes to engage, in unfair competition, as 21 defined in Business and Professions Code section 17200. 22 22. Health and Safety Code section 25181 authorizes the Court to issue an order that 23 enjoins any ongoing or potential violation of the HWCL, or of any applicable rule, regulation, 24 permit, standard, requirement, or order issued or promulgated pursuant to the HWCL. 25 23. Health and Safety Code section 25515.6 authorizes the Court to issue an order that 26 enjoins any ongoing or potential violation of Chapter 6.95. 27 24. Health and Safety Code sections 25184 and 25515.8 provide that in civil actions 28 brought pursuant to the HWCL, or Chapter 6.95, respectively, in which an injunction or temporary -5— COMPLAINT FOR INJUNCTIVE RELIEF, CIVIL PENALTIES, AND OTHER RELIEF