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What is an Environmental Crime?

Violations of environmental laws take many different forms. Some are done intentionally and may be criminal violations.

Typical environmental  violations which result in investigations may involve, but are not limited to:

  • Illegal disposal of hazardous waste
  • Export of hazardous waste without the permission of the receiving country
  • Illegal discharge of pollutants to a water of the United States
  • The removal and disposal of regulated asbestos containing materials in a manner inconsistent with the law and regulations
  • Conspiracy
  • Money laundering relating to environmental criminal activities

Violation Scenario

Containment areas set up prior to abatement. This ensures that no asbestos fibers will enter non-abatement areas


The owner of an apartment complex solicits bids to remove 14,000 square feet of old ceiling tiles from the building. Three bidders inspect the building, determine that the tiles contain dangerous asbestos fibers, and bid with understanding that, in doing the removal, they would be required to follow the work practice standards that apply to asbestos removal. The fourth bidder proposes to save the owner money by removing the tiles without following the work practice standards. The owner hires the fourth bidder on this basis and, so, the work is done without following the work practice standards. The owner is guilty of a criminal violation of the Clean Air Act.

Remember: Your Safety Comes First!

Do not put yourself in harm’s way. Please review these safety tips and do not try and investigate on your own – report what you see at

  • If you are not sure that an area is safe, stay away
  • Do not enter confined spaces or low-lying areas
  • Do not lean over open waste containers, or kick, rock or puncture waste containers
  • If trained to enter, wear appropriate protective gear
  • Do not take samples unless trained
  • Keep others away from the scene until assistance arrives
  • Be sure to keep children and pets away
  • Do not track toxic material into your car

For more information on environmental crime, see Criminal Investigations – Violation Types and Examples  or review the Report an Environmental Violation – General Information Brochure.

Asbestos Tidbid for July

Hi everyone! Vern, Jr. here.

I trust you all had a happy and safe Independence Day…

Allow me to take this opportunity to announce that I will be taking over the monthly tidbit festivities. Vern Sr. is doing fine and will be pulling back a little. He has prepared me extremely well to fill his shoes, and I get the feeling he’ll be wearing flip-flops a little more often nowadays, but we will still be in contact (most of the time!)…

I have been teaching the lion’s share of our classes in the past year, and I am very excited about the prospect of developing a solid and trusting intellectual relationship with each and every one of you. I am grateful for the opportunity to serve your training and coaching requirements, and I look forward to providing you with the level of service and expertise you have naturally come to expect from Vern Roberts Environmental Training, Inc.

As many of you know, we have moved from the Treasure Island location to 4902 113th Ave N., Clearwater, FL 33760. We are at the north end of the building (Emerald City Comics) and it is about a mile or two from I-275.

Recently, I was asked to clarify a few points about who’s responsibility it is to notify building occupants about an upcoming abatement project under a few different scenarios. The questions regarding notification requirements are as follows:

Are there any specific notification requirements for doing abatement in an occupied building for the following scenarios:

A) If the abatement is to occur during working hours (when occupied)
B) If the abatement is to occur after hours when no employees should be present
C) if the abatement is to occur after hours and there is a chance a few employees could be there

These questions are answered a few different ways…
My first response would be to ascertain the class of work involved. Assuming that the idea of setting up a containment points to Class I work (the REMOVAL of Thermal System Insulation or Surfacing Material), I would automatically submit the required 10-day notification to the local NESHAP office. As for the building occupants, it is the responsibility of the building owner to notify these folks. As a Contractor, prior to beginning the project, I would ask the building owner to set up a meeting with the various occupants. I would participate in the meeting and serve to field questions from the occupants and explain what is about to take place. This might not be within the building owner’s area of expertise.

A “Regulated Area,” defined under OSHA 1926.1101 as “an area established by the employer to demarcate areas where Class I, II, and III asbestos work will be conducted, and any adjoining area where debris and waste from such asbestos work will accumulate…” is the area an asbestos contractor considers his own, and NO unauthorized persons are allowed to enter. As such, there are NO requirements to the occupants other than the DUTY of the OWNER to notify the occupants about the presence of a hazardous or toxic substance in the building they are occupying.

Refer to 1926.1101(k)(2)(iii) A, B, and C; also 1926.1101(k)(2)(ii) D

It sounds complicated, but it might be a topic of discussion in of my upcoming refreshers… 🙂

Please check the website Home Page for dated and times. Since your schedule might be tight, I can always adjust my schedule to accommodate yours.

If all else fails, call me on 727-239-1445 to set it up. I look forward to hearing from you!!!

Stay Safe…

Asbestos Tidbid for April

Hello All!!  After almost 6 years at the same location in Treasure Island we have moved the classroom to a  New location.
 florida photo
Follow the  “Yellow Brick Road”  to “Emerald City Comic Book” store at the corner of 49th street and 113th Avenue… U really cannot miss it there is a HUGE sign on the south side of 49th and at the corner of 113th Emerald City…clear across the county….closer to Tampa
On with the tidbit… Here are a few numbers that you all should have an interest in, but first
Lettuce congratulate the newest LAC to the fold! Mona J. has studied  all the regs and passed the State of Florida test for Licensed Asbestos Consultant!!   (VRET’s study guide, a tome of 800+ multiple choice questions was a help)
EPA’s clean air = .01 f/cc
Osha’s @ 1926.1101 P.E.L.= .1 f/cc as 8 hour TWA
Osha’s @ 1926.1101 E.L.= 1 f/cc over a 30 minute period
Osha’s @ 1926.1101 the 25/10 rule for class 1 work = Hygiene Facilities  (J) are included in the D-con.
Osha’s @ 1910.134 For QNFT with 1/2 mask the minimum # must achieve 100 or more. for the F/Face, the # must achieve 500 or more to pass.QLFT is Pass/fail, no #s
Keep in mind Osha @ 1926.1101 defines “PACM”, and the word “INTACT”(among others)
EPA, Neshap @ 61.141 defines “Adequately Wet”, “Friable”, ” RACM”,and “Poor condition.  (among others)
EPA, Neshap. @61.145, Formal Notification is 10 working days in advance of the projects start date.
EPA Neshap @61.141 defines cat 1 NF and cat 2 NF(among others)
Ahera @ 763 defines Significantly Damaged, Damaged and Good.( among others)
EPA Neshap @ 61.145= square linear and cubic footage of RACM that MUST be notified on if exceeding these amounts 160 sq, 260 linear or 35 cubic feet.
EPA Neshap @ appendix A (the roofing section of the Neshap) 5,580 square feet when using the “R/B Cutter….. This is the Threshold Amount .Below this amount U can use whatever method to remove the roof it is NOT regulated by the Federal Neshap… (Always a good Idea to check the local county DEP if they differ)
Anything above not fully understood?? You may need a refresher,  give us a call at 727-385-4213 and make the arrangements…we are fully accommodating and MOST knowledgeable about these matters… plus we make it fun!!… Supervisor, Inspector, Planner, Designer, Respiratory Protection  (Initials and refreshers)
 Visit or visit and sign into refreshers On-Line! either way you will receive the best training from our Florida, and Tennessee certified staff.
Thanks and see ya in Class!!  Vern Sr and Vern Jr
Vern Roberts Environmental Training
Service Connected Disabled Veteran ,SDVOSB
Classroom ,10681 Gulf Blvd Treasure Island Florida, 33706
Phone 727-593-3067, Cell, 727-385-4213,
Fax 727-517-4111
Ahera Asbestos Classes when you want them!!
Visit for our On-Line classes


Asbestos Tidbid for March

If Senator Bob Graham had an aunt named Anna, would she be “Aunt Anna Graham”??
On with the tidbit… Osha ‘s 1926.1101 states they will not accept a composite sample from Dry wall and dry wall compound… Yet, EPA suggests a composite sample of dry wall and dry wall compound is OK.
Conflicting Agencies?? Not at all… One must understand the difference between these agencies.
Lettuce go to Osha first, The determination of asbestos in dry wall compound is done by sampling by layer… Not a composite sample… Each layer is read by PLM and the determination is made for asbestos content. Osha wants the people who may come in contact with the asbestos in the compound to be protected while they remove these systems from a building. The Asbestos Contractor, in Florida will establish a NEA on all the tasks associated with this Class 2 removal and follow waste disposal guidelines accordingly
Go to 1926.1101 and look up Osha’ position on Dry Wall and compound over nail holes and seams.
EPA on the other hand, has established rules for compositing these materials.
It is impossible to separate the two materials from each other. The composite sample can result in the material being less than 1 % asbestos thus eliminating the Neshap especially in the areas of disposal, but NOT OSHA!
Where the renovation or demolition is about to occur it would be the smart LAC to sample accordingly to the needs and regulations of these two great agencies… And the smart Florida asbestos contractor to do the removal tasks under Osha’s class two requirements.
Anything not understood in the above? Maybe U need a refresher course… We offer the traditional classroom activity and NOW U can take the class on your PC at home in your spare time ON-Line!
Go to and follow the prompts… yep, its that simple!!!


Asbestos Tidbid for February

Hello All!! be glad and thankful we are NOT shoveling 24 inches of additional “Partly Cloudy” from our walkways.

snow photo

On with the tidbit!

The Inspector is out and about conducting a survey. The edifice is about to undergo a massive  renovation.

The edifice is NOT a school building, rather a large apartment complex, built in the early sixties.
What protocol (s) does he fall under?

There are three concerns here… first is the Neshap @ 61.145 which states the owner or operator will have the building inspected for the presence of asbestos and will include Cat 1 and Cat two non friable materials, Prior to the reno.

The second concern is OSHA @ 1926.1101.(H) while taking the samples as per the (third) Ahera Protocol,should he be wearing a respirator??

OSHA classifies sample taking as Class 3 work and to be exempt from wearing a respirator/protective clothing he MUST have a Negative Exposure Assessment for all the materials he is about to sample. Even the non friable? No, only for the friable materials that will be disturbed. Unless the non-friable has become friable. Non-friable material such as floor tiles or roofing materials are easily sampled with a sharp instrument that will CLEAVE into the material and not create dust.

Osha is clear at 1926.1101 (H) on who needs to be in a respirator and when the need it…. Lettuce follow their rules and play it safe….

Anything above not understood? call my cell and book a refresher or go to and take the Refreshers U need On-Line!!!

How about the chips off the old block!!! Vern Jr., my eldest son, just passed his State Abestos Contractor’s test.

My youngest son Stephen,was just selected as Principal to the school he is teaching K-12 ….

Tis a proud day for the Old Man

Asbestos Tidbid for January

Hello All, WOW!! The New Year is here… Lettuce hope everyone has a happy and prosperous new year!!

champaign photo

On with the tidbit… When is a respirator needed?? What respirator to use? What Osha classification of work are we doing?, What are the “expected fiber counts for this work?

Complex? No not if you know how Osha is stepped. Step one, Win the job, step two, Classify the job, (class one,two ,three or four under Osha 1926.1101 ). Step three, ascertain what the fiber counts will be after installing the necessary engineering controls, Step four, now select your respirator.

Understand there is an exception here…

For class one work and NO negative exposure assessment up front and the fiber counts are expected to be at 1 F/CC or LESS, you MUST be in the PAPR. (minimum).

For class one work and again no NEA, and the counts are expected to be above 1 f/cc you need to be in the Type C PP,PD with an auxiliary tank on hip at a minimum .

Take a look at the MUC for each respirator and apply the one that fits for other classifications of work.

For instance, Class three work and the F/cc is less than 1 the 1/2 face will work very well.

For class two work that will generate a fiber count above 5 f/cc you need to be in the PAPR. What class two work will do this? Ceiling tiles will generate enormous counts. You need to know the material you are about to disturb and take all the information about it into context.

Anything here NOT understood?? You need to come to a class or visit and take one or more of our courses!! We now have the Supervisor, Inspector, Planner and Project Designer, either way on-line or in the classroom

Happy New Year!!

Vern & Vern Jr.

Asbestos Tidbit for October

Hello All!!!   The “fall” is here!!   looking at more comfortable temperatures?  look at Minot (someplace up nawth) it is 21 degrees!  fugetthabotit!!!  I love the heat!!!!
On with the tid-bit… There are two inspection types that result in the identification of asbestos containing materials. The one that we all learned from the initial class was all about the Ahera school inspection. Remember?  Probably not… The Ahera inspection was all about the Identification, location, footage, and the overall condition of the material.(physical assessment )
The Ahera report, when finished would be presented to the Management Planner who in turn would act upon the materials after converting the “Physical assessment” to the  “Hazard assessment” and then applying grease to the squeakiest wheels by application of EERRO. Any asbestos not removed would be involved in a Plan held by the local LEA and kept under periodic surviellance.
The OTHER inspection is one hardly mentioned but today is the root of many problems the contractor or owner incur when renovating or demolishing their property.
This Inspection is completed in compliance with the Federal NESHAP @ 61.145 and requires the owner or operator of a reno or demo to THOURHOUGHLY inspect the premises for the presence of asbestos containing materials including Cat 1 and Cat 2 nonfriables.
The Ahera and Neshap inspections need to be kept apart… The management planner is NOT a part of the Neshap. So why put the asbestos found into a plan ?? The Planner is NOT a mandated part of the public or commercial building unless the owner chooses to follow the Ahera Protocol.
Anything here not fully understood?? U need to call me or come on down to a refresher.
Make the refresher easier U can take it “On-Line ” at and select from our menu.
Seeya in class!!! stay warm!!   Vern

Asbestos Tidbit for September

Hello ALL!  long hot summer, take a look at “google earth” , input Greenland Ice Sheet to see the latest .
greenland photo
On with the tidbit.  The contractor wins the job to remove TSI and Surfacing (Class 1, work under 1926.1101)
He sends in the 10 day notification form to the local DEP as required under the Neshap,  61 .145 (M)
Prior to beginning, He studied the job  (Initial exposure assessment) and decides to put his people into “Type C” PP,PD with a SCBA tank also in PP-PD on hip for this removal.
WHY? lettuce # the answers
  1. He had NO  current negative exposure assessment .
  2. Osha regulations state respiratory protection will be selected after reducing or eliminating the danger, via engineering controls.
  3. His initial exposure assessment of this job indicates the exposures during gross removal will be >1F/CC after all engineering controls are in place.
  4. He can certainly down grade when the required daily Osha monitoring of ALL tasks indicates either negative or at or below 1F/CC as an 8 hour TWA ….. Above 1F/CC & Class1 work & no NEA, he MUST be in the highest level (1926.1101, respiratory selection.)
So U understand everything above?? if yes call and wish me a Happy BDay on the 19th of September.
Something here U don’t understand… Call me immediately,  wish me a happy BDay before the 19th and get the answers U need!!
Taking a refresher in the future??? STOP!! & go to and click on any of these…Supervisor,Inspector,Planner and Project Designer refreshers follow the prompts. YES!! ON-Line.
We now accept Government Credit Cards thru a special account we set up at Regions Bank nationwide.
Want to come to the classroom? no problem, just call and let me know when U want a class.
Seeya in Class Vern


Asbestos Tidbit for April

question photo
Hello All, This tidbit is for the  Ahera Supervisor, Ahera Designer and Florida’s LAC.
Usually I make mention of a regulation pertaining to our work. This tidbit is a bit different..It is a question for all of the above mentioned.
On to the question;  The Built up asphaltic/bituminous roof is over 6 thousand square feet, It surveyed out at 7% asbestos (yes, Ed P. the necessary # of samples were taken) and it is in good condition.The building will be demolished.
Using the “RB cutter” the abatement contractor says he will put a certain amount of the asbestos waste into a “Neshap approved ” and the rest can go to a construction debris landfill… What is What here?? Can he do this??
Immediate responders will be told the correct answer according to the current federal regulation.
Answers for the lollygaggers will appear in next month’s tidbit. 
The On-Line refreshers are up and running …here they are; The Supervisor, Inspector,Planner, and Designer Refreshers all can be taken On-Line …just visit and select from the menu.
Thanks and seeya in class Vern and Vern Jr.


Asbestos Tidbit for March

Hello All!
water photo
One would guess we need the rain and snow to replenish the aquifers and lakes for the nations water supplies… Tampa may have the answer with its latest de-sal plant…  25 million gallons per day with cost over runs that went into the hundreds of millions… reverse osmosis may be the answer but at what expense?
On with the tidbit…last month I stated the Osha ‘S Pel was .01 f/cc as an 8 hour TWA …
Not one soul out there picked this up … The Osha Pel is .1 f/cc! and U had a chance  to crash at Ole Vern…
Based on .1 f/cc the Supervisor as well as the Project Designer will check on what material will give off or emit fibers BEFORE the removal process begins and then install the four engineering controls… then apply respiratory protection for the removal people. According to OSHA’s 1926.1101 , this is the way things are done.
Each respirator has a Number issued by Niosh and that # multiplied by Osha’s PEL will result in the Maximum Use Concentration for that mask.  For class one work, if the competent person estimates the fiber count to be at or less than 1f/cc the mask MUST be the PAPR… Not understood?? Come on down and sit a spell at my classroom… I will show ya where it is at in the Federal Regulations My classes are not opinions they are facts from the feds! (and there is always a bit of humor injected into the subject matter.
See ya in class