The Alabama Department of Environmental Management issued a September 28 order to Gerhardi, Inc., addressing alleged violations of Alabama hazardous waste regulations.
Walter Wright, Jr.The ADEM ordered a fine of $18,550 for the German-based Gerhardi, which is a tier one automotive supplier that makes class A parts by plastic injection molding processes and hot stamping. The company says it is “one of the largest developers and producers on the market for electroplated and technically demanding plastic parts in Europe.”
GI is stated to operate an automotive part manufacturing facility with an EPA Identification Number in Montgomery, Alabama. The facility is stated to be a large quantity generator of hazardous waste as defined in ADEM Admin. Code Div. 14.
A representative of ADEM’s Industrial Hazardous Waste Branch conducted a compliance evaluation inspection of GI on January 28th. The compliance evaluation, inspection, and a review of GI’s compliance are stated to have indicated the following:
- GI failed to make waste determinations on the following containers:
- Three 250-gallon totes of unidentified waste are located in the electroplating line area.
- Twelve 250-gallon totes of unidentified waste are located in the electroplating area ‘s outside storage area.
- Failure to submit an appropriate notification to ADEM in writing, no less than 30 days before the expected date of ceasing operation of the area located between the wastewater treatment system and the electroplating area's loading dock as a hazardous waste central accumulation area.
- Offering hazardous waste for transport to a company that did not have an EPA Identification Number and an Alabama Hazardous Waste Transport Permit.
- Storage of hazardous waste for more than 90 days without a permit or being granted an extension.
- Storage of hazardous waste in the secondary containment pit for more than 90 days, thereby creating a hazardous waste tank.
- Failure to properly manage satellite accumulation containers of hazardous waste.
- Failure to keep closed certain satellite accumulation containers.
- Failure to mark or label certain satellite accumulation containers with the words "Hazardous Waste" and with an indication of the hazards of the contents.
- Failure to maintain required documentation at the facility.
- Failure to provide for review documentation that the facility inspected the hazardous waste accumulation area weekly.
- Failure to provide for review documentation that facility personnel who manage hazardous waste had completed an annual review of the initial hazardous waste training.
- Failure to provide for review documentation of all job descriptions related to hazardous waste management.
- Failure to submit an ADEM Form 8700-12 to the Department annually.
- Failure to provide for review copies of its hazardous waste manifests.
- Failure to include a list of all emergency equipment, the equipment’s location, and a physical description of the equipment in its contingency plan.
- Failure to provide for review documentation that the facility's contingency plan had been sent to all local emergency responders.
The Order proposes a civil penalty of $18,550.00. A copy of the Order can be downloaded at https://adem.alabama.gov/sites/default/files/2025-09/09-25gerhardi.pdf.
Walter Wright has more than 30 years of extensive experience in environmental, energy (petroleum marketing) and water law. He counsels clients on issues involving environmental permits, compliance strategies, enforcement defense, property redevelopment, environmental impact statements, and the procurement/management of water rights. Visit www.mwlaw.com.
