NJDEP A-901 • WASTE • SOIL AND FILL
Received an A-901 Inquiry? Organize the Actual Business Record.
An A-901 integrity inquiry may reach beyond company operations to disclosures about owners, managers and other key persons. Waste, hauling and soil/fill businesses should organize the actual agency request, license history and relevant records before deciding how to respond. This checklist provides a focused starting point for a confidential legal review without assuming that every inquiry is an accusation of wrongdoing.
1. Identify the document and deadlines
- Identify the legal entity, license number, regulated activities and precise agency unit issuing the request.
- Keep the complete correspondence, attachments, date received and any requested response or conference date.
- Collect the original Business Concern Disclosure Statements and annual updates, not just revised summaries.
- Locate Personal History Disclosure Statements for relevant key employees and principals.
- Collect parent-company and second-level disclosure documents, if applicable.
2. Preserve and reconstruct the facts
- Create an ownership chronology from company formation through current principals, members, officers and managers.
- Preserve organizational charts, formation records, contracts, financing and leasing arrangements that explain actual control.
- Reconcile what the company submitted previously with current ownership and operations; identify gaps without silently correcting historic submissions.
- Separate A-901 background, integrity or disclosure issues from facility permits and environmental operational issues.
- Preserve original records. Do not change documents, conceal management arrangements or discourage truthful cooperation.
3. Evaluate process, representation and business consequences
- Identify current NJDEP, Division of Law and State Police roles in the particular request.
- Determine whether the inquiry affects an initial application, annual update, business restructuring or potential adverse action.
- Ask counsel to review the precise notice and governing legal process before submitting contested factual assertions.
- Consider appropriate environmental or other specialized co-counsel where permit, contamination or criminal issues overlap.
Why this matters
NJDEP says A-901 licensing involves evaluation of integrity, reliability, expertise and competence with input from the Attorney General and State Police. In some situations, an owner’s or key employee’s disclosures may be central to the inquiry.
Never assume that preparing this checklist pauses a legal deadline, authorizes noncompliance with inspections, or replaces legal advice from an attorney competent in the actual proceeding.
Practical next steps
Use the checklist to assemble a non-privileged description of the relevant notices, source records and deadlines. Discuss sensitive details only with counsel through appropriate secure channels. This educational list is not an engagement and does not guarantee any outcome.
Regulator source and related services
Official NJDEP A-901 guidance · Other regulated-industry resources
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