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Real cost of a Notice of Violation (NOV)

Direct Cost:

  • Notice of Violation (NOV) letter: $200
  • Explanation to the Management on reasons for NOV: 10 hour
  • Response to Management on other EHS compliance status: 40 hour
  • Management time to make decisions: 1 hour
  • Procurement time to issue check: 1 hour
  • New checks & balance instituted by Management to avoid NOV: 40 hour

Total cost: $200 & 92 hour (@$100/hour): $9,400

Indirect Cost:

  • Impact on investor relationship: $$$
  • Impact on public perception: $$$
  • Impact on operations due to increased enforcement & scrutiny: $$$
  • Impact on permitting schedule during facility expansions: $$$

Potential Cost to the EHS Manager:

  • Disenfranchised supervisor and Management
  • Transfer or loss of job

As you may have recognized…the real cost to the business is much more than the $200 NOV from the regulatory agency. Unfortunately, many fail to realize the significance of resource allocation to maintain environmental compliance and how important it is to never get an NOV.

Joshi Environmental, Inc. (JEI) recommends that every facility should review its environmental compliance at least once every three years. A knowledgeable auditor can identify areas needing improvement and the audit report can be used as a guide to improve and maintain environmental compliance.

To discuss the importance of environmental compliance assessments, or to schedule an environmental assessment of your facility, please contact Sam Joshi at (215) 389-2811.