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ComplianceLogger

ComplianceLogger - Site Disclaimers

Last Updated: January 15, 2025

⚠️ THIS IS NOT A GOVERNMENT WEBSITE ⚠️

IMPORTANT LEGAL NOTICE:

COMPLIANCELOGGER IS NOT:

  • AFFILIATED WITH THE U.S. ENVIRONMENTAL PROTECTION AGENCY (EPA)
  • ENDORSED, SPONSORED, OR APPROVED BY EPA OR ANY GOVERNMENT AGENCY
  • AN OFFICIAL GOVERNMENT TOOL OR SERVICE
  • A GUARANTEE OF REGULATORY COMPLIANCE

⚠️ IMPORTANT: Read Before Using This Service

PLEASE READ CAREFULLY:

ComplianceLogger is a documentation tool designed to help you organize waste disposal records. It is NOT a substitute for professional environmental consulting, legal advice, or regulatory compliance services.

1. General Disclaimer

Not Legal or Environmental Advice

ComplianceLogger does NOT provide legal, environmental, or regulatory advice.

  • Information provided by this Service is for general informational purposes only
  • Content should not be relied upon as professional advice
  • Always consult qualified environmental professionals, attorneys, or regulatory agencies for advice specific to your situation

No Attorney-Client or Consultant-Client Relationship

  • Use of ComplianceLogger does not create an attorney-client relationship
  • Use of ComplianceLogger does not create a consultant-client relationship
  • We are a software tool provider, not a law firm or environmental consulting firm

2. EPA Compliance Disclaimer

No Guarantee of Compliance

USING COMPLIANCELOGGER DOES NOT GUARANTEE COMPLIANCE WITH EPA REGULATIONS.

ComplianceLogger:

  • ✅ IS a tool to help you organize waste disposal documentation
  • ✅ CAN help you track waste types, quantities, dates, and disposal locations
  • ✅ MAY assist with recordkeeping for EPA audits or inspections

ComplianceLogger:

  • ❌ IS NOT a guarantee that your records will satisfy EPA requirements
  • ❌ DOES NOT ensure compliance with RCRA or other environmental laws
  • ❌ CANNOT determine whether your waste is hazardous or subject to specific regulations
  • ❌ DOES NOT replace professional hazardous waste determination services
  • ❌ WILL NOT protect you from EPA enforcement if you violate environmental laws

Regulatory Responsibility

YOU are solely responsible for:

  • Understanding which environmental regulations apply to your operations
  • Determining whether your waste is hazardous
  • Complying with all federal, state, and local waste management requirements
  • Obtaining necessary permits and EPA identification numbers
  • Following proper manifest procedures for hazardous waste
  • Meeting recordkeeping and reporting requirements
  • Ensuring the accuracy of all information you enter

3. EPA Affiliation Disclaimer

Not EPA Endorsed or Affiliated

COMPLIANCELOGGER IS NOT:

  • Affiliated with the U.S. Environmental Protection Agency (EPA)
  • Endorsed, sponsored, or approved by EPA
  • Certified or validated by EPA
  • An official EPA tool or service
  • Authorized to speak on behalf of EPA

EPA Has Not Reviewed This Service

  • EPA has not reviewed or approved ComplianceLogger
  • EPA has not verified the accuracy of information provided by ComplianceLogger
  • EPA has not tested or certified this Service for compliance purposes

References to EPA

When ComplianceLogger references EPA regulations, guidance documents, or recordkeeping requirements:

  • These references are provided for informational purposes only
  • Information may be outdated, incomplete, or inaccurate
  • Always verify regulatory requirements with official EPA sources
  • EPA regulations change frequently; ComplianceLogger does not guarantee current information

Official EPA Resources

For authoritative EPA information, consult:

  • EPA Official Website: https://www.epa.gov
  • EPA RCRA Regulations: 40 CFR Parts 260-282
  • EPA Hotline: (800) 424-9346 (RCRA/Superfund Hotline)
  • EPA Regional Offices: https://www.epa.gov/aboutepa/visiting-regional-office
  • State Environmental Agencies: Contact your state's environmental protection department

4. Data Accuracy Disclaimer

User Responsibility for Accuracy

YOU are solely responsible for the accuracy, completeness, and truthfulness of all data you enter into ComplianceLogger.

ComplianceLogger:

  • Does NOT verify or validate the information you enter
  • Does NOT audit your waste management practices
  • Does NOT confirm that your records are accurate or complete
  • Cannot determine if your entries reflect actual waste disposal events

Consequences of Inaccurate Data

Entering false, misleading, or inaccurate information:

  • May violate federal and state environmental laws
  • May result in civil penalties (up to $81,000+ per day per violation)
  • May result in criminal prosecution
  • May invalidate your records in EPA enforcement proceedings
  • May damage your credibility with regulators

No Data Verification

ComplianceLogger does NOT:

  • Cross-check your entries against manifests or receipts
  • Verify disposal locations are legitimate facilities
  • Confirm hauler licenses or certifications
  • Validate manifest numbers or EPA ID numbers
  • Detect fraudulent or falsified entries

5. Reconstructed Records Disclaimer

"Audit Mode" and Reconstructed Records Warning

If you use ComplianceLogger's "Audit Mode" or enter records marked as "RECONSTRUCTED" or "ESTIMATED":

⚠️ CRITICAL WARNINGS:

  1. Reconstructed records are estimates based on your recollection, not contemporaneous documentation
  2. Reconstructed records may have limited evidentiary value in EPA enforcement proceedings
  3. EPA may NOT accept reconstructed records as proof of compliance
  4. Reconstructed records should be clearly marked as estimates when presented to regulators
  5. Creating reconstructed records does NOT excuse past noncompliance with recordkeeping requirements

Good Faith Requirement

If creating reconstructed records:

  • You must act in good faith and provide your best recollection
  • You must NOT falsify or fabricate records to mislead regulators
  • You must clearly disclose the reconstructed nature of records to EPA
  • You should timestamp records to show when they were created vs. when disposal occurred

EPA Audit Policy

ComplianceLogger references EPA's Audit Policy (also called the Self-Policing Policy), which may provide incentives for voluntary disclosure and correction of violations.

IMPORTANT:

  • The EPA Audit Policy has specific requirements (systematic discovery, voluntary disclosure, prompt correction, etc.)
  • Using ComplianceLogger does NOT automatically qualify you for Audit Policy benefits
  • Consult an environmental attorney to determine if you qualify for Audit Policy protection

EPA Audit Policy Resources:

  • EPA Audit Policy: https://www.epa.gov/compliance/epas-audit-policy

6. Hazardous Waste Determination Disclaimer

ComplianceLogger Does NOT Determine Hazardous Waste Status

Determining whether your waste is hazardous requires:

  • Knowledge of waste characteristics (ignitability, corrosivity, reactivity, toxicity)
  • Understanding of EPA hazardous waste listings (F-list, K-list, P-list, U-list)
  • Chemical analysis or testing (in some cases)
  • Application of the mixture rule and derived-from rule
  • State-specific regulations (which may be more stringent than federal)

ComplianceLogger:

  • ❌ Does NOT test or analyze your waste
  • ❌ Does NOT determine if your waste is hazardous
  • ❌ Cannot tell you if you need an EPA ID number
  • ❌ Cannot tell you if you need to use hazardous waste manifests

Hazardous Waste Classification

If you generate waste that may be hazardous:

  • Consult a qualified environmental professional or laboratory
  • Use EPA's hazardous waste determination resources
  • Contact your state environmental agency
  • Err on the side of caution (when in doubt, treat as hazardous)

Misclassifying hazardous waste can result in:

  • EPA enforcement action
  • Civil penalties (up to $81,000+ per day per violation)
  • Criminal prosecution (for knowing violations)
  • Environmental cleanup liability
  • Third-party lawsuits

EPA Hazardous Waste Resources:

  • Hazardous Waste Determination: https://www.epa.gov/hw/defining-hazardous-waste-listed-characteristic-and-mixed-radiological-wastes
  • Generator Categories: https://www.epa.gov/hwgenerators

7. Limitation of Liability

Use at Your Own Risk

YOU USE COMPLIANCELOGGER AT YOUR OWN RISK.

  • ComplianceLogger is provided "AS IS" without warranties of any kind
  • We make no guarantees about accuracy, reliability, or fitness for your compliance needs
  • We are NOT liable for EPA enforcement actions, fines, penalties, or other consequences arising from your use of the Service

See our Terms of Service for full limitation of liability provisions.

8. State-Specific Requirements

State Regulations May Differ

Many states have environmental regulations that are more stringent than federal EPA requirements.

ComplianceLogger:

  • Primarily references federal EPA regulations
  • May NOT include state-specific requirements
  • Cannot determine which state regulations apply to you

YOUR RESPONSIBILITY:

  • Research your state's environmental regulations
  • Contact your state environmental agency
  • Comply with both federal AND state requirements
  • Consult local attorneys or environmental consultants familiar with your state's laws

State Environmental Agencies:

  • Find your state agency: https://www.epa.gov/home/health-and-environmental-agencies-us-states-and-territories

9. Record Retention Disclaimer

Retention Periods

ComplianceLogger may reference EPA's 3-year recordkeeping requirement for waste generators. However:

  • State laws may require longer retention periods
  • Certain violations may extend retention requirements
  • Pending litigation may require indefinite retention
  • Your insurance or business practices may require longer retention

YOU are responsible for:

  • Determining applicable retention periods for your records
  • Maintaining backups of your data
  • Exporting data before canceling your subscription
  • Complying with all retention requirements

10. Third-Party Services Disclaimer

External Services

ComplianceLogger may link to or integrate with third-party services (e.g., payment processors, cloud storage).

We are NOT responsible for:

  • Third-party privacy practices
  • Third-party data security
  • Third-party service availability
  • Accuracy of third-party information

Review the terms and privacy policies of any third-party services you use.

11. Changes and Updates

Regulatory Changes

Environmental regulations change frequently. ComplianceLogger:

  • Does NOT guarantee that information is current
  • May not reflect recent regulatory changes
  • Does NOT automatically notify you of regulatory changes

YOUR RESPONSIBILITY:

  • Stay informed about regulatory changes
  • Subscribe to EPA updates and newsletters
  • Consult current regulations before making compliance decisions

Service Changes

ComplianceLogger may change features, content, or disclaimers at any time. Continued use constitutes acceptance of changes.

12. Emergency Situations

Not for Emergency Use

ComplianceLogger is NOT designed for emergency situations.

In case of:

  • Spills or releases: Contact your state environmental agency and/or National Response Center (800-424-8802)
  • Immediate health threats: Call 911 or local emergency services
  • Hazardous waste emergencies: Contact EPA Emergency Response (varies by region)

Do NOT rely on ComplianceLogger for emergency response guidance.

13. Professional Consultation Required

When to Consult Professionals

You should consult qualified professionals in these situations:

  • Determining whether your waste is hazardous
  • Obtaining EPA ID numbers or permits
  • Preparing for EPA inspections or audits
  • Responding to EPA enforcement actions or notices of violation
  • Interpreting regulatory requirements
  • Implementing compliance management systems
  • Conducting voluntary disclosures under EPA Audit Policy

Types of Professionals:

  • Environmental attorneys
  • Environmental consultants
  • Hazardous waste management firms
  • Certified industrial hygienists
  • Chemical testing laboratories

14. International Users

U.S.-Focused Service

ComplianceLogger is designed for U.S. waste generators and primarily references U.S. EPA regulations.

If you are located outside the United States:

  • ComplianceLogger may NOT be suitable for your compliance needs
  • Consult your country's environmental regulations
  • Seek advice from local environmental professionals

15. Severability

If any provision of these disclaimers is found invalid or unenforceable, the remaining provisions remain in full effect.

16. Acknowledgment

BY USING COMPLIANCELOGGER, YOU ACKNOWLEDGE AND AGREE THAT:

  1. ✅ ComplianceLogger is a documentation tool, not a compliance guarantee
  2. ✅ You are solely responsible for regulatory compliance
  3. ✅ You will verify all information and consult qualified professionals
  4. ✅ ComplianceLogger is not affiliated with or endorsed by EPA
  5. ✅ You accept all limitations of liability and disclaimer terms
  6. ✅ Reconstructed records may have limited evidentiary value
  7. ✅ You will not rely on ComplianceLogger as a substitute for professional advice

17. Contact Information

For questions about these disclaimers:

Lexopoly LLC Email: [email protected] Website: https://compliancelogger.lexopoly.com

For EPA Regulatory Questions: Contact EPA directly (NOT ComplianceLogger):

  • EPA Hotline: (800) 424-9346
  • EPA Website: https://www.epa.gov

Quick Reference: What ComplianceLogger IS and IS NOT

| ComplianceLogger IS | ComplianceLogger IS NOT | |---------------------|-------------------------| | ✅ A documentation and organization tool | ❌ A guarantee of EPA compliance | | ✅ A way to track waste logs digitally | ❌ Legal or environmental advice | | ✅ A resource for recordkeeping | ❌ EPA-affiliated or endorsed | | ✅ Helpful for audit preparation | ❌ A hazardous waste determination service | | ✅ Useful for organizing photos and receipts | ❌ A substitute for professional consulting | | ✅ A tool for exporting reports | ❌ Verification of data accuracy | | ✅ Support for proactive and reactive tracking | ❌ Validation of compliance status |

Document Version: 2.0 - Customer-Facing Edition Last Updated: January 15, 2025 Internal Legal Analysis: See LEGAL_ANALYSIS_FINAL.md for comprehensive case law citations and legal reasoning