What is a Toxic Release Inventory (aka TRI, SARA 313, Form R)?

What is a Toxic Release Inventory (aka TRI, SARA 313, Form R)?

Mar 26, 2024

What Is It?

TRI first came into existence in 1986 as part of the Superfund Amendments and Reauthorization Act (SARA) and Emergency Planning and Community Right-to-Know Act (EPCRA). TRI’s creation was influenced by an event in Bhopal, India in 1984 where a cloud of toxic gas from the Union Carbide chemical plant killed thousands. Then in 1985 a serious chemical release occurred to a similar chemical plant in West Virginia. EPA wanted a way for the public to learn more information about the chemicals used in their communities so it setup a reporting system for companies using potentially harmful chemicals above certain thresholds.

What’s the Difference Between TRI, Form R and SARA 313?

There are other names that are often used to refer to TRI reporting.

The first is “SARA 313.” TRI reporting is covered under Section 313 of SARA. Thus, TRI reporting is also referred to as “SARA 313” reporting. Other SARA reporting requirements include SARA 311 and 312 which are the Tier II chemical inventory reporting requirements we covered in our EPCRA Tier II blog, SARA 304 which is emergency spill reporting, and SARA 302 and 303 which cover emergency planning and notification requirements.

TRI reporting can also be known as “Form R” reporting. This is because one of the names of the forms used for TRI reporting is called Form R.

Reporting Criteria

In order to qualify for TRI reporting, your company must meet this criteria:

  • Employ 10 or more employees;
  • Fall under an identified NAICS code from the 2017 NAICS list; and,
  • Manufactures, processes, or uses a chemical on the TRI list of approximately 770 chemicals at a threshold above allowed levels. These chemicals have been identified as ones with significant effects to the environment or human health.  Chemicals are continually being added to this list.

2022 Updates

Due July 1, 2022:

  • All natural gas processing facilities that receive and refine natural gas are now subject to reporting.
  • Four PFAS chemicals have also been added:  silver(I) perfluorooctanoate (335-93-3), perfluorooctyl iodide (507-63-1), potassium perfluorooctanoate (2395-00-8), and 2-Propenoic acid, 2-methyl-, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12,12-heneicosafluorododecyl ester, polymer with 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluorodecyl 2-methyl-2-propenoate, methyl 2-methyl-2-propenoate, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12,13,13,14,14,14-pentacosafluorotetradecyl 2-methyl-2-propenoate and 3,3,4,4,5,5,6,6,7,7,8,8,8-tridecafluorooctyl 2-methyl-2-propenoate (65104-45-2).
  • 29 contract sterilization facilities now must estimate their quantities of ethylene oxide and/or ethylene glycol manufactured, processed or otherwise used to determine if they are subject to TRI reporting.

In the previous reporting year (due July 1, 2021), over 172 PFAS chemicals were added to the list of chemicals and the thresholds for these were significantly less than other chemicals.

Report Format

TRI uses two different forms for reporting, Form R and Form A.  First, you will use Form R to identify chemicals.  For the rest of the reporting, you need to continue with Form R or use Form A.  Form A is a shortened form and only available if your company meets certain criteria in type of chemical, quantity, and waste generated. If you don’t meet the criteria for Form A, then you must use the longer Form R.

A form (R or A) must be completed for each chemical you manufacture, process or use in quantities above the threshold.

How are TRI Reports Submitted?

TRI reports are completed federally through EPA’s TRI-MEweb website. You will need to make copies to submit to your state agency as well.

This information will become public information and be searchable in several online databases.

Supplier Notifications

Companies who process or manufacture chemicals or chemical mixtures are required to send annual supplier chemical notifications per EPCRA Section 313.  For more details on who and what that entails, check out our blog “Annual Supplier Notifications: Does This Affect Your Company“?

Have Questions? Need Help?

Do you need help with this environmental reporting requirement? iSi’s compliance team can help determine if you are required to submit and help you get the forms submitted. Contact us here for more information and pricing.

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Which Environmental Regulations Apply to Emergency Power Generators?

Which Environmental Regulations Apply to Emergency Power Generators?

Mar 17, 2024

Emergency power generators can be critical pieces of equipment for any facility, especially in the stormy seasons of spring or winter or in disasters such as floods and the hurricanes of summer and early fall. If you have one in your facility now, or are thinking about getting one, you need to be aware of the environmental regulations which are triggered by having one onsite.

EPA defines emergency generators as “…stationary combustion devices, such as reciprocating internal combustion engine or turbines that serve solely as a secondary source of mechanical or electrical power whenever the primary energy supply is disrupted or discontinued during power outages or natural disasters that are beyond the control or operator of a facility.” There are no time limits to using emergency generators during an emergency, but there are limits to the number of hours a generator can be used in non-emergency situations such as maintenance, testing, and other occasions such as offsetting electrical demand or to reduce electrical costs.

The bigger the generator, and the older the generator, the more likely environmental regulations will be triggered. The type of fuel used to power the generator also affects compliance. Generators can run on diesel fuel, gasoline, propane or natural gas.

The following environmental regulations may be triggered by your emergency generator:

Air Emissions

Emergency generators can have the potential to emit various air pollutants such as carbon monoxide, volatile organic compounds, xylene, carbon dioxide, sulfur dioxide, and others.

Depending on your state or local environmental regulations and the type of generator you have, you may need to prepare and file for an air permit whether it be a general permit, an operating permit, or a construction permit.

There are specific rules which govern the various types of generator engines. 40 CFR 60, Subpart IIII is for stationary compression ignition generators, 40 CFR 60, Subpart JJJJ is for stationary spark generators, and 40 CFR 63, Subpart ZZZZ applies to reciprocating internal combustion engines (RICE). Each regulation has strict operating guidance and compliance obligations.

Spill Prevention, Control and Countermeasures (SPCC)

If the fuel which you store onsite is in a tank with aboveground storage above 1,320 gallons, you will need to prepare an SPCC plan. SPCC Plans identify discharge prevention potential, discharge prevention measures and tasks, training, and the procedures to be followed if a spill does occur.

Emergency Planning and Community Right to Know Act (EPCRA)

If your fuel storage is above certain amounts, you will be required to conduct EPCRA annual reporting, chemical inventorying, and notifications. (For more information about EPCRA read our EPCRA blog article.)

Tank Certifications and Registrations

Aboveground and underground fuel storage tanks may need to be registered, permitted, inspected, and certified per state and local regulations.

PCBs

A potential for the presence of polychlorinated biphenyls (PCBs) can be found in any transformers, capacitors, electrical equipment, thermal insulation and motor/hydraulic oils. Cleanups, exposures and removals would need to be handled according to EPA’s PCB regulations.

Employee Exposure Issues

Though technically a safety issue, any backup generator which is brought into a facility could cause additional employee exposure issues. Before the use of generators, noise monitoring would need to be conducted to determine the potential noise exposures to employees in the area. Exhausts emitted from indoor generators may cause additional issues with employee exposure to chemicals, causing the need for engineering controls or additional employee personal protective equipment use.

Which Environmental Regulations Apply to Your Emergency Power Generator?

The regulations which apply to emergency power generators can vary greatly depending on style, type, model, your location, facility setup and other factors. What are your specific permitting requirements? Let iSi figure this out for you. Contact us for more information about environmental obligations, or ask us for a pricing quote to take a look at your situation.

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EPA Makes Final Rule to Update RMP Requirements

EPA Makes Final Rule to Update RMP Requirements

Mar 15, 2024

EPA has issued a change to its Risk Management Program, or RMP regulations for those who process, produce, handle or store hazardous substances or chemicals.  The changes are in an amendment to the rule, officially called the Safer Communities by Chemical Accident Prevention, or SCCAP.  These new rules hope to help increase protection for human health and environment from chemical hazards using lessons learned and process safety procedures.

First, What’s RMP?

RMP can be found in EPA’s Clean Air Act.  If you produce, process, handle or store one of 140 targeted toxic or flammable chemicals that have the potential to be released at certain threshold quantities, then you fall under RMP requirements.  Some examples of the 140 chemicals included are ammonia, chlorine, propane, formaldehyde and sulfur dioxide.

Water treatment plants, agricultural COOPs and chemical manufacturers are typical types of companies who need to comply with RMP.

RMPs must include:

  • Hazard assessments
  • Potential effects of a chemical accident
  • 5-year accident history
  • Evaluation of worst-case scenarios and alternative accident release potentials
  • Prevention programs that include safety precautions, maintenance, monitoring, and employee training measures
  • Emergency response program that lists emergency health care, employee training measures, procedures for informing the public.

RMPs are similar to OSHA’s Process Safety Management (PSM) standard, but RMP is concerned with protecting the environment and human health while PSM is focused on protecting the worker.  Unlike PSM, RMPs are directly submitted to EPA and information is input into a public database for transparency purposes.

Program Levels

A number of the changes are related to specific program levels of RMP.  There are 3 levels to RMP:

Program 1

Processes which would not affect the public in the case of a worst-case release and with no accidents with specific offsite consequences within the past five years.  These sites have limited hazard assessment and minimal prevention and emergency response requirements.

Program 3: 

This is for processes not eligible for Program 1 and are either subject to OSHA’s PSM standard or have one of 10 specified North American Industrial Classification System (NAICS) codes (NAICS code 32211, 32411, 32511, 325181, 325188, 325192, 325199, 325211, 325311, or 32532).  This program requires using OSHA’s PSM standard as your prevention program plus there are additional hazard assessment, management, and emergency response requirements.

Program 2:

If you don’t fit into Program 1 or 3, then you are a Program 2.  This program imposes streamlined prevention program requirements, as well as additional hazard assessment, management, and emergency response requirements.

The Rule Changes

Emergency Response

  • RMP facilities must develop procedures for informing the public about accidental releases.
  • Release notification data must be provided to local responders.
  • A community notification system must be in place for RMP-reportable accidents.
  • Field exercises must be conducted every 10 years unless local responders indicate that’s infeasible.
  • Emergency response exercises are to follow mandatory scope and reporting requirements.

Third-Party Compliance Audits

  • A third-party must do the next scheduled compliance audit when an RMP-regulated facility experiences two RMP-reportable accidents within five years or when a Program 3 facility under NAICS 324 or 325 has one reportable accident within one year AND that facility sits within one mile of another NAICS 324 or 325 process facility.

Program Requirements

  • Facility siting must be considered in Program 2 hazard reviews and Program 3 process hazard analyses.
  • When facilities have a reportable accident, a formal root cause analysis incident investigation must be conducted.
  • Program 2 hazard reviews and Program 3 process hazard analyses must now address natural hazards (including those resulting from climate change) and power losses.
  • Whenever a recommendation from a hazard evaluation, facility siting, or a third-party compliance audit is not adopted, a justification needs to be put into the RMP.

Employee Participation

  • Employee participation is required in resolving process hazard analyses, compliance audit and incident investigation recommendations and findings.
  • Employee participation is required for stop work procedures in Program 3.
  • Program 2 and 3 sites must provide opportunities for employees to anonymously report RMP accidents or issues of non-compliance.

Safer Technologies and Alternatives Analysis (STAA)

  • A STAA evaluation is required for all Program 3 NAICS 324 and 325 processes.
  • A Practicability assessment of inherently safer technologies and designs (IST/ISD) should be considered if your process falls within one of these conditions:
    • It’s a Program 3 under NAICS 324 and 325 within one mile of another Program 3 NAICS 324 or 325 process,
    • It’s a process under NAICS 324 using with hydrofluoric acid alkylation,
    • You’ve had one RMP accident since the facility’s most recent process hazard analysis.
  • Implement at least one passive measure at the facility, or IST/ISD, or a combination of active and procedural measures equivalent to or greater than the risk reduction of a passive measure for the same facilities required to conduct the practicability assessment.
  • When STAA recommendations are not adopted, then you must provide justification.

Communication

  • The facility must now provide chemical hazard information, upon request, to residents living within 6 miles of the facility in the language they request.

Other

  • Hot work permits must be kept for 3 years.
  • Program 2 and Program 3 requirements should be consistent for recognized and generally accepted good engineering practices.
  • Program 3 process safety info must be kept up to date.

Compliance Dates

The SCCAP is effective May 10, 2024.  There are two separate compliance dates.  Emergency response field exercise frequencies are due by March 15, 2027, or within 10 years of the date of an emergency response field exercise conducted between March 15, 2017 and August 31, 2022.

The following items are due three years after Final Rule publication (May 10, 2027)

  • Root cause analyses
  • Third-party compliance audits
  • Safer Technologies and Alternatives Analysis (STAA)
  • Employee participation
  • Emergency response public notification
  • Exercise evaluation reports

More Information

If you have questions or need assistance in determining if your facility is required to comply with RMP, or if you need help getting one setup, contact us!

Need Assistance?

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Which Annual Environmental Training Should You Add to Your Calendar?

Which Annual Environmental Training Should You Add to Your Calendar?

Jan 31, 2024

Recently we covered the required annual OSHA safety training requirements your company should be scheduling each year.  What about the most common annual EPA or environmental training requirements?

RCRA Hazardous Waste

Training is required for anyone handling or managing hazardous waste. For large quantity generators this training is required annually by federal regulations. For conditionally exempt small quantity generators and small quantity generators, annual training is not specified in the federal regulations but is considered a best practice.

Many states have their own hazardous waste regulations which can vary from the federal version and even be stricter, so be aware of the regulations for your area. For example, in Kansas, small quantity generators are specifically required to have annual training.

Stormwater Pollution Prevention Plan (SWP3)

Training is required annually for any facility required to have a Stormwater Pollution Prevention Plan, and in some locations, additional training may also be required. iSi did a stormwater training project for a client who had facilities in 48 states, and one of the modules we produced had a clickable state map where the learner could go learn about the rules for their state.   In our research, we found stormwater rules can vary greatly from state to state, and in some cases, from municipality to municipality.  State general permits have expiration dates on them and will be updated when the new one is issued, so check with your state’s environmental agency and find their general permit to see what the rules are.

[Don’t have time to look it up?  Contact us and we can get you pricing to have one of our environmental team members look up the most recent permit for your state(s) and determine what your requirements are, and what your training needs to cover.  (We can do the training too or make the slides for you if you need it.)]

Spill Prevention, Control and Countermeasures (SPCC)

Any company required to have an SPCC Plan must conduct training annually.  SPCC Plans ensure facilities have containment and other countermeasures in place to prevent oil spills from reaching navigable waters. Annual training is required for oil-handling personnel to ensure the prevention measures and procedures are in place, understood and followed.  This training should include the procedures and policies written in your SPCC plan.

Facility Response Plan (FRP)

FRPs are plans regarding oil spill responses after the spills occur. For those who are required to have FRPs in accordance with 40 CFR Part 112, there is training required as well as hands-on exercises. The National Preparedness for Response Exercise Program (PREP) is to be used for the hands-on portion and the U.S. Coast Guard’s Training Elements for Oil Spill Response can be used for the classroom training.

Qualified individual and emergency procedures exercises must be conducted quarterly, equipment deployment exercises must be conducted semiannually, and incident management team tabletop exercises must be conducted annually. There are additional requirements for unannounced and after business hour training.

This is different from HAZWOPER, which is an OSHA requirement, but you could incorporate some of the exercises as part of your annual HAZWOPER training.

Asbestos

Those certified as asbestos workers, contractor/supervisors, inspectors, planners and project designers are required to complete annual refresher training.

On the OSHA side, maintenance personnel who may disturb asbestos within the course of their duties are required to have annual awareness training. Although EPA addresses awareness training for these workers, it’s OSHA that requires the training annually.

Others Worth Mentioning

TSDF facility personnel must have RCRA emergency response training, and that training can be HAZWOPER if it meets the RCRA requirements. HAZWOPER refresher training is due annually.

There are other annual environmental training requirements for industrial processes which are not as widespread including municipal solid waste combustors, medical waste incinerators, and underground hazardous waste injection wells. Much of this training is also conducted by EPA or state-approved training providers.

Others Required, but Not Annually:

  • NESHAP Subpart HHHHH (6H) for Paint Stripping and Surface Coating Operations:  Every 5 years
  • Risk Management Plans: Every 3 years
  • Pesticides: Every 5 years
  • Lead-Based Paint (Lead Renovation, Repair and Painting Rule (RRP)): Every 3-5 years depending on the initial test you took
  • DOT (for hazardous waste manifest signing): Every 3 years
  • IATA (for air shipments of hazardous materials): Every 2 years
  • IMDG (for vessel shipments of hazardous materials): Every 3 years

Annual OSHA Safety Training

If you missed our blog on annual OSHA safety training needed, you can find that here.

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State, Regional and National Safety and Environmental Conferences for 2024

State, Regional and National Safety and Environmental Conferences for 2024

Jan 22, 2024

We exhibit and speak at many different safety and environmental conferences throughout the region.  What’s the schedule look like for 2024?

Here is a list of some upcoming state, regional and national safety and environmental conferences that you may want to add to your calendar.  (For now, we’re listing the ones near where we have offices. )

We will work to keep this list updated as we find out changes, if any.

Central U.S. / Region VII

 

Region VII (KS, MO, IA, NE)

Midwest Environmental Compliance Conference (MECC)
Sept. 24-25 | Overland Park | In-Person and Online | Learn More

Region VII VPPPA Midwest Safety and Health Conference
TBD | Des Moines | Learn More

Kansas

KDHE Environmental Conference
Aug. 7-8 | Wichita | In-Person | Learn More

Kansas Safety and Health Conference
Oct. 1-2 | Wichita | In-Person| Learn More

Missouri

Mid-America Safety, Health & Environmental Conference and Expo
TBD | Springfield | In-Person | Learn More

Greater St. Louis Safety & Health Conference
Oct. 1 | St. Louis | In-Person | Learn More

Missouri Hazardous Waste Seminar
April 30 | Online | Learn More

Safety & Health Council of Western Missouri & Kansas SAFECONEXPO
May 14-16 | Lake Ozarks, MO | In-Person | Learn More

Nebraska

Nebraska Safety & Health Summit
Oct. 14  | Omaha | In-Person | Learn More

Iowa

Hawkeye on Safety
Sept. 5 | Coralville | In-Person | Learn More

Iowa Governor’s Safety & Health Conference
Oct. 29-30  | Des Moines | Altoona | Learn More

Central U.S. / Region VI

 

Region VI (OK, TX, NM, LA, AR)

Region VI VPPPA
April 30 – May 2 | Oklahoma City, OK | In-Person | Learn More

Oklahoma

Oklahoma Safety and Health Conference
July 24-26 | Norman | In-Person | Learn More

Environmental Federation of Oklahoma (EFO) Annual Meeting & Trade Show
Oct. 14-17 | Midwest City | In-Person | Learn More

Southeast / Region IV 

 

Region IV (GA, AL, MS, KY, TN, NC, SC, FL)

Region IV VPPA Safety + Symposium
Aug. 25-28 ​ | Aurora, CO | In-Person | Learn More

Georgia

Georgia Environmental Conference
Aug. 21-23 | Jekyll Island | In-Person | Learn More

Georgia Safety, Health and Environmental Conference
Sept. 4-6 | Savannah | In-Person | Learn More 

Tennessee

Chattanooga Regional Manufacturers’ Association Environmental, Health and Safety Summit
TBD | Chattanooga | In-Person | Learn More 

Tennessee Environmental Network Show of the South
May 15-17 | Chattanooga | In-Person | Learn More 

Alabama

Alabama Governor’s Safety and Health Conference
Aug. 26-28 | Orange Beach | In-Person | Learn More

Manufacture Alabama HR, Safety & Environmental Conference
TBD | Birmingham | Learn More

North Carolina

NC Statewide Safety Conference
TBD | Learn More

Carolina Star Safety Conference
Sept. 18-20 | Greensboro | In-Person | Learn More

Eastern Carolina Safety & Health Conference
Apr. 10-12 | Atlantic Beach | Learn More

South Carolina

South Carolina Environmental Conference
Mar. 10-13 | Myrtle Beach | In-Person | Learn More

ASSP Region VI Conference
Sept. 18-20 | Virginia Beach | In-Person and Online | Learn More

NSC Southeast Regional Conference & Expo
May 14-16 | Rosemont, IL | Learn More

National Conferences


American Industrial Hygiene Conference and Expo (AIHCE) EXP 2023 
May 20-22 | Columbus, OH | Learn More 

American Society of Safety Professionals (ASSP) Conference and Expo
Aug. 7-9  | Denver, CO | In-Person and Online | Learn More

National Safety Council (NSC) Safety Congress
 Sept. 13-19 | Orlando, FL | In-Person| Learn More

Associated General Contractors (AGC) Construction Safety, Health & Environmental Conference
July 16-18 | St. Louis, MO |  In-Person | Learn More

Associated General Contractors (AGC) Construction Safety & Health Conference
Jan. 10-12  | Newport Beach, CA |  In-Person | Learn More

Alliance of Hazardous Materials Professionals (AHMP) National Conference
July 14-17 | Kansas City, MO | Learn More

National Association of Environmental Professionals (NAEP) Annual Conference and Training Symposium
May 5-8 | Minneapolis, MN | Learn More

National Environmental Health Association (NEHA) Annual Education Conference & Exhibition
TBD | Spokane |  In-Person and Virtual | Learn More

Which safety and environmental conferences did we miss?  Let us know by emailing us here.

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Hazardous Waste Biennial Reports Due March 1

Hazardous Waste Biennial Reports Due March 1

Jan 15, 2024

Every even-numbered year, large quantity hazardous waste generators must submit their Biennial Hazardous Waste Reports by March 1.

The rule is part of EPA’s Resource Conservation and Recovery Act (RCRA) hazardous waste regulations. It requires facilities to report the nature, quantities and disposition of hazardous wastes generated every 2 years. Treatment, storage, and disposal facilities (TSDFs) are also required to make a report of the wastes they’ve received from off-site.

Your facility must complete biennial hazardous waste reports if you generate 2,200 lbs. of hazardous waste in any calendar month. You may have additional state requirements and thresholds to consider as well.

Biennial hazardous waste reporting typically applies to large quantity generators, but state regulations may vary for small quantity generators, conditionally exempt small quantity generators and other state-specific categories of generators.

These reports are sent to your authorized state agency or EPA regional office, depending on where your facility is located and your state rules.

Need help in determining if you’re subject to this reporting? Need help filling out the paperwork and submitting it? Let iSi take care of this report for you! Contact us today for more information and pricing.

 

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2024 EPA and OSHA Compliance Deadlines

2024 EPA and OSHA Compliance Deadlines

Jan 5, 2024

It’s a new reporting year and time to plan for reporting and compliance deadlines from 2023’s activities and for the new year.  Mark your calendars with these environmental and safety reporting deadlines and other to-do tasks for 2024:

EPA/Environmental

 

OSHA/Safety

 

DOT/Transportation

State and Local Reporting Dates

There are other environmental and/or safety reports you must complete, but due dates may vary according to your state and local regulations or when your permits or reports were first completed.  Some examples include:

  • Title V Air Permits (Semi-Annual Compliance Certifications)
  • Hazardous Waste Reports
  • Wastewater Discharge Certifications and Monitoring Reports
  • Aboveground and Underground Storage Tank Registrations
  • Groundwater Monitoring Reports
  • Air MACT Certifications, Deviation Reports and Summary Reports
  • Stormwater Reports, Inspections and Sampling
  • Boiler Reports
  • X-Ray Equipment Registrations

Stay tuned to our blog for any updates or notices of new regulations.

Because environmental and safety regulations vary from state to state, city to city, there may be additional requirements for your company which are not listed above.  If you need assistance in determining which of these apply to you, or assistance with completing these reports and permits, iSi would love to help!  Please contact us for more information and pricing.

 

 

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Inspection Data Shows Common Hazardous Waste Violations

Inspection Data Shows Common Hazardous Waste Violations

Nov 28, 2023

We decided to take a look at some of the EPA enforcement sites to review hazardous waste violations issued across the U.S. within the past couple of years.  We wanted to see if there were some common themes that readers should be on the lookout for because sometimes the best lessons can be learned from the experience of others.  We chose, at random, sites from all across the U.S. and looked at the federal citations (not state citations) noted.  

Here are some of the most common items we found.  How well is your company managing these items?

Container and Labeling Issues 

The top 2 areas that kept coming up, maybe because they could be considered low hanging fruit, were related to container management and labeling.  

Container issues included:

  • Keeping containers closed
  • Keeping containers in the waste storage area past the required time limit per generator status
  • Keeping incompatible wastes separated during accumulation
  • Not enough aisle space between drums
  • Container condition issues such as cuts and dents
  • Not having proper spill and leak prevention and cleanup supplies
  • Not immediately cleaning up spills and leaks

Labeling issues were basically incorrect labels to not having any labels at all.  Improper labeling examples included not marking drums as “Hazardous Waste” or not marking used oil storage containers as “Used Oil.”  This was not limited to just hazardous waste, but also included not marking universal wastes what they were, such as spent bulbs.  There were also several instances of containers not having the accumulation start dates marked on them.

Inspections

One of the next most popular items cited was hazardous waste inspections.  Companies either didn’t do them at all, did not document them, or did not do them adequately.  

Make sure this is something you are doing and documenting.  Make sure your inspectors are just not going through the motions and checking the same boxes.  Are the items considered out of compliance showing up on the checklist each week?  If so, why aren’t they being addressed?  If you find items out of compliance, were they noted on the last inspection and why or why not?

Training

Many companies were cited for not providing training or not providing it annually, where applicable.  Different levels of generators have different training requirements depending on federal regulations and specific state regulations, however, it was one of the areas most cited. 

In one instance, a company was fined for not having job titles and job descriptions for each position in the facility related to hazardous waste management.  This is a requirement for large quantity generators on a federal level (and may be an additional state requirement depending on which state you’re in). We have seen job titles and descriptions asked for in DOT hazmat inspections as well.  This is to help inspectors determine who at the facility needs to have training. Then once they know who needs training they will ask for employee start dates to determine timeframes so they can calculate when initial and refresher trainings should have been conducted.

Waste Determinations

Several companies were fined for not conducting waste determinations.  This is one of the first things you need to be doing so that you know the hazards of the waste you’re storing and how you will need to properly manage it.

Contingency Plans

A number of companies had contingency plan issues.  Some of these included:

  • Not having a contingency plan when required to
  • Not describing what the company’s response would be to fires and explosions in the plan
  • Not including an evacuation plan
  • Not listing emergency equipment capabilities in the plan

Tanks and Air Emissions 

Many tank-related issues were cited, but not only about the tanks themselves, but the air emissions issues related to tanks.  In a previous blog, we wrote about how there are air emissions regulations written into the hazardous waste regulations.  Subparts BB and CC of the RCRA air regulations pertain to tanks.   EPA’s 2021 compliance initiatives included a statement that said a number of facilities were not complying with RCRA air requirements and as a result, inspectors were being directed to look at these items in inspections. Some of the air-related violations included:

  • Failing to comply with emissions control standards for tanks
  • Failing to comply with regulations regarding leaks such as marking equipment subject to Subpart BB air emissions standards
  • Not developing a monitoring plan for valves that are difficult or unsafe to monitor
  • No calibration testing
  • Not passing the required leak test requirements and not having records showing passing scores every 30 days for the past 12 months
  • Not doing required monthly monitoring

Some examples of the tanks-only (not related to air) violations included:

  • Storing hazardous waste in a tank for more than 90 days
  • Not doing daily inspections
  • Not having hazardous waste tank inspection records
  • Not doing periodic testing and monitoring of spill prevention equipment or containment sumps
  • Not having a qualified engineer assess the integrity of an existing tank used to store hazardous waste
  • Not conducting annual line tightness testing for underground storage tanks

Other Items

There were a number of other items cited that appeared less often, but are still worth mentioning.  They include:

  • Storing hazardous waste without a permit or without notifying the local authority that they had hazardous waste onsite
  • Not following the conditions of their hazardous waste permit
  • Not complying with manifest requirements and not completing them correctly
  • Not following hazardous waste transportation regulations or following regulations for proper disposal
  • Not meeting land disposal requirements
  • Not submitting biennial reports

Conclusion

With the majority of the cases, more than one item was cited.  Some of the fines for single violations fell within the $5,000 area while most with multiple citations were $50,000-$100,000.  Some companies were allowed to pay about half in fines and then spend the other half to do supplemental purchases of emergency response equipment for their local fire departments.  That was used in a few instances, especially in the central states.

Does your facility have any of these issues?  Do you need help with a contingency plan? Do you need to get caught up on your worker training?  Do you need someone to come evaluate your entire program to see where your gaps are?  iSi can help with all things hazardous waste.  Contact us today with any questions or for some pricing for us to lend you a hand.

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EPA Looks to Add Air Emissions Reporting Items

EPA Looks to Add Air Emissions Reporting Items

Aug 18, 2023

EPA has announced a several changes to its Air Emissions Reporting Rule, or AERR that would make reporting of hazardous air pollutants (HAPs) consistent from state to state, add electronic reporting of stack tests, decrease and standardize emissions thresholds, create earlier reporting deadlines, and add new point sources to reporting requirements.

All of the changes EPA is considering making is to help the agency comply with the presidential commitment to enhance environmental justice by gathering more detailed location-specific information.

HAP Reporting

Per the AERR, industry is already required to report emissions of common or criteria pollutants and the pollutants that form them, called precursors.  Right now, the federal rule doesn’t require HAP reporting, but some states require reporting and voluntarily give this information to EPA.  Not all states do, and not all Indian lands do either.  For the ones that do, the rules can vary greatly from state to state.

The new rule would make HAP reporting standard for all facilities in all states who are:

  • Major sources per Clean Air Act operating permits;
  • Non-major sources who were in a certain industry emitting HAPS at or above a certain threshold;
  • Indian lands; and,
  • Offshore deep water ports.

Facilities would also be required to provide other details and data about HAPs from their stack test and performance evaluations.  EPA would like these to be reported electronically through the Consolidated Emissions Data Reporting Interface (CERDI).

To help states find a way to make reporting this data to EPA be more streamlined without the need to create their own separate data collection programs, EPA would like for states to develop procedures to have industry use the online Combined Air Emissions Reporting System, or CAERS system.  CAERS is already in use for reporting National Emissions Inventories and Toxic Release Inventories (TRI).  EPA even hopes to work towards eventually using CAERS to gather Greenhouse Gas Reporting (GHG) data and incorporate the CERDI as well.

The new rule would start in 2027.  This is because states have told EPA it can take two to three years for them to change their air emissions regulations.  EPA also says time it can take states to migrate from their current systems to CAERS could be one to three years as well.

Shorter Deadlines

The proposed rule looks to make states work faster to get this data to EPA.  Right now, states have 12 months after the end of the reporting period to turn in inventory data.  That is, the reporting period ends on December 31, and EPA has until December 31of the following year to turn it in to EPA after receiving it from industry much earlier than that. Starting in 2027, state inventory data would be due to EPA by September 30 and starting in 2030, data would be due by May 31.

Many states already turn in their collected inventory data sooner than that 12-month deadline, but shortening the due dates may force all states to go to electronic systems and may cause some of them to move up due dates for industry.

If EPA’s goals of using CAERS for multiple emissions reports, EPA speculates the possibility arises industry may eventually see one consolidated deadline for all reports rather than the current tiered deadlines of GHG reports due March 31, some air emissions reports due May 31 and TRI reports due July 1.  Another possibility to help alleviate stress in the deadlines in this case would be for industry to potentially report some data directly to EPA rather than go through the state.

EPA is currently seeking comments about the timing of the phase in deadlines and EPA wants feedback on these potential scenarios.

Standardized Emissions Thresholds

Under the current AERR rule, states report data on criteria pollutants and precursors that exceed certain thresholds.  The thresholds are setup to be different each year over a triennial cycle. That is, they are higher in the first two years and then lower in the third year.  On that third year, more facilities end up qualifying for reporting.  The new rule would make the threshold the same each year.  That would be the lower year 3 emissions threshold, causing more facilities to need to report every year.  HAP thresholds would be the same each year as well.

Small Generating Unit Emissions Data Included

Some facilities use small generating units to help meet demand on high electricity demand days or use them to supplement their own electricity.  EPA wants to make these a new source reporting requirement, taking daily data such as fuel use or heat input.  EPA says that when facilities use a number of these at one time, the units can significantly add to ozone formation through emitting of nitrogen oxides and particulate matter.

Currently, emissions for these are reported as an annual, not daily, emissions value and only if they’re located at a point source.  If they’re not located at a point source, they aren’t tracked at all.  The new rule would track all of them at all facilities.

Prescribed Fire Data

The proposed rule would also add the requirement for state, local and tribal forestry agencies to report daily activities associated with prescribed fires on state, tribe, private, or military lands.  This would include fires affecting more than 50 acres where there is forest canopy present (understory fire) or where there is little forest canopy like a grassland or oak woodland fire (broadcast fire), or pile burns of 25 acres or more.

Agricultural fires, land clearance fires and construction fires would not be included.

Comments Period

The public is invited to comment on the proposed rule up until October 18, 2023.  You can find the entire rule HERE.

Need Help Sorting This Out?

If you have questions about air emissions reporting in general, anything discussed in this article or this proposed rule, or need help getting your environmental reporting taken care of, we’re here to help!  Contact iSi today!

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What the Haz?

What the Haz?

May 19, 2023

A Deeper Dive Into the “Haz” Words in OSHA, EPA and DOT and Where They Can Crossover

Every once in a while, we will get a call from someone looking for “Hazmat” training.   To you, the word hazmat may mean one thing, but we guarantee to someone else it probably means something completely different.

iSi’s mission is to help companies navigate compliance with EPA, OSHA and DOT regulations.  Once you start familiarizing yourself with those regulations, you will find that the definition of hazmat can be different for different agencies and different situations.   You will also see that there are a number of words that include “haz” that can creep into the picture and be used interchangeably.  An even deeper dive will show that each agency will either make up their own definition or borrow from one another.

Each Agency Has Its Own Focus

Regulations and their definitions are typically written in the perspective of the focus of the agency.  Each agency has its own role to play in the workplace and how they use their haz words will often be reflective of that.

  • OSHA – OSHA’s focus is safe and healthful working conditions for workers
  • EPA – EPA’s focus is on human health and the condition of the environment
  • DOT – DOT’s focus is on the safe, efficient, sustainable and equitable movement of people and goods

Once you know the perspective for each, that will help you be able to better understand regulations when they crossover or refer to one another.

Hazmat

Hazmat is a shortened version of “hazardous materials.”  Each agency refers to hazardous materials a little differently.

In OSHA, the term hazmat can refer to hazardous materials or hazmat teams.  OSHA says a hazardous material is something that can be a health hazard or a physical hazard.  However, a hazmat team is an organized group of employees who perform work to handle and control spills or leaks of hazardous substances.  Individually trained members of the hazmat team are called hazardous materials technicians.  Later we’ll look at the OSHA HAZWOPER standard where many of these definitions are found.

To DOT, hazmat means “a substance or material capable of posing an unreasonable risk to health, safety, and property when transported in commerce…”  It also can include hazardous substances, hazardous wastes, marine pollutants, elevated temperature materials, materials listed in the Hazardous Materials Table, and materials meeting their criteria for hazard classes and divisions. The term Hazmat employee in the regulations are those persons who package or prepare, physically transport, load, unload, design or makes packages for, fills out paperwork for or ensures the safe transportation of hazardous materials.

To EPA, a hazardous material is any item or chemical which can cause harm to people, plants, or animals when released by spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping or disposing into the environment.

From the definitions, you can see that OSHA was focused on people, DOT was focused on transportation and EPA was focused on the environment.

HazCom

Another shortened haz word is HazCom.  This is short for the OSHA Hazard Communication Standard.  This standard is all about hazardous chemicals, that is, any chemicals that are a physical or health hazard. The HazCom Standard deals with Safety Data Sheets (SDS), labeling, markings, training and more.

EPA’s Emergency Planning and Community Right to Know Act, or EPCRA, regulations refer to OSHA’s hazardous chemicals when it comes to which chemicals apply to the EPCRA regulation.  Those which fall under the HazCom standard and have SDSs associated with them are included in EPCRA reporting requirements.  Some companies also refer to HazCom training by the term Employee Right to Know training.

Hazardous Waste

Another haz is hazardous waste. The term hazardous waste comes from EPA’s Resource Conservation and Recovery Act (RCRA) hazardous waste regulations.  There’s a lengthy determination process one must go through to even determine if something can be defined to be a hazardous waste.  You’ll see all of those criteria and the roadmap in the definition of hazardous waste at 40 CFR 261.2.

EPA’s website says, “Simply defined, a hazardous waste is a waste with properties that make it dangerous or capable of having a harmful effect on human health or the environment. Hazardous waste is generated from many sources, ranging from industrial manufacturing process wastes to batteries and may come in many forms, including liquids, solids gases, and sludges.”

Hazardous waste must be discarded and must be a solid waste.  To be a solid waste, it must be a material that has been abandoned, recycled, is inherently waste-like or is a military munition.

Once you determine that it’s discarded and a solid waste, there are another set of questions to ask to make the determination if a waste is hazardous or not.  This process is quite important and is required to be completed and documented for each of your wastes.

OSHA mentions hazardous waste in their HAZWOPER standard, calling hazardous waste anything that’s found to be a hazardous waste by the EPA definition or anything that DOT calls a hazardous waste in their definition.

In DOT regulations, DOT says hazardous waste is defined under EPA’s definition and that to ship hazardous waste a hazardous waste manifest is required.  Hazardous waste is a hazardous material that is regulated for transportation. So when a vendor comes to pick up your hazardous waste, your company is the one technically shipping it and are therefore subject to all of the DOT hazmat regulations the same as if you were shipping any other hazardous material.

Hazardous Substances

All 3 agencies use the term hazardous substance.

In EPA, a hazardous substance is “Any substance, other than oil, which, when discharged in any quantities into waters of the U.S., presents an imminent and substantial danger to the public health or welfare, including but not limited to fish, shellfish, wildlife, shorelines and beaches (Section 311 of the Clean Water Act); identified by EPA as the pollutants listed under 40 CFR Part 116.”  Hazardous substances are referred to in the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, aka Superfund), the Clean Water Act (CWA), the Clean Air Act (CAA), the RCRA hazardous waste regulations, and the Toxic Substances Control Act (TSCA).

OSHA makes it easy.  They say a hazardous substance is whatever EPA CERCLA says it is, whatever DOT says are hazardous materials, whatever EPA says a hazardous waste is, or any other biological or disease-causing agent that could lead to things like death, disease, behavioral abnormalities, cancer, genetic mutation, physiological malfunctions or physical deformations in such persons or their offspring.

DOT says a hazardous substance is a hazardous material when that material is listed in their Appendix A and when its single package exceeds the reportable quantity listed in the Appendix. They also have other considerations if it’s a mixture or solution or a radionuclide.

HAZWOPER

And finally, there’s HAZWOPER.  Although it’s one of our more popularly discussed haz words, we left this for the end because this regulation actually uses all of the haz words in one place and seems to be one standard that incorporates so many different requirements from all 3 agencies within it.

HAZWOPER stands for Hazardous Waste Operations and Emergency Response.  HAZWOPER is found in the 1910 General Industry Standards under Subpart H, Hazardous Materials.  An identical copy can be found under a different subpart in the 1926 Construction Standards.

There are 3 main pieces or goals to HAZWOPER:

  1. Rules for conducting cleanup operations at sites determined to be EPA RCRA hazardous waste cleanup sites, cleanup operations at sites contaminated by hazardous substances on uncontrolled hazardous waste sites that EPA or another government agency have required to be cleaned up, or conducting voluntary cleanups at those same types of uncontrolled waste sites;
  2. Operations at treatment, storage and disposal facilities (TSD) regulated by EPA RCRA; and,
  3. Emergency response to releases of hazardous substances at any facility, any location.

Being an OSHA regulation, HAZWOPER is all about protecting the worker and the public during the cleanup, so all the guidance centers around preparing for and safely cleaning up hazardous substances.

The regulation mentions the term Hazmat teams in relation to those responding to the emergency responses found in part 3 of the standard.

HAZWOPER says any materials cleaned up and containerized into drums must meet appropriate regulatory requirements for DOT transportation, RCRA hazardous waste and OSHA safety regulations.  Waste must be transported per DOT regulations while self-contained breathing apparatuses used by workers to protect themselves during work are to comply with DOT standards.

The DOT’s Emergency Response Guidebook is mentioned and often consulted for emergency response information and guidance.

If a company has prepared a contingency plan per EPA requirements and that plan includes emergency response information, the company can use that contingency plan as part of its emergency response plan so that efforts are not duplicated.

On the EPA side, because OSHA regulations don’t apply to local and state governments, EPA has adopted the HAZWOPER standard into 40 CFR 311 to apply to those local and state governments and any of those not covered by a state OSHA-approved plan.

Also in EPA, emergency spills trigger a whole host of reporting requirements as well as emergency response plans and training to protect the environment from hazardous waste spills, oil spills, pipeline leaks and chemical releases to water, air or land.

Conclusion

This is not an exhaustive list of haz references or examples where all 3 agencies cross over, but hopefully it gave you an idea of how these terms and the rules related to them can be so different in some cases, but so intertwined in others.  The haz words used can differ depending on the situation.

So, if you call us asking for hazmat training, you’re likely to get a lot of questions from us about your end goal.

What haz words have you come across?  What examples did we miss?  We’ll be posting this on our Facebook, LinkedIn, Twitter and Instagram pages.  We’d love to hear from you!  

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CSB Issues Safety Alert Regarding Emergency Pressure Relief Systems

CSB Issues Safety Alert Regarding Emergency Pressure Relief Systems

Apr 21, 2023

The Chemical Safety Board (CSB) has issued a safety alert regarding emergency pressure relief systems as the agency is continuing to see them playing their part in major chemical incidents.

Who is the CSB?

The CSB is an independent federal agency who investigates the root causes of chemical incidents at industrial sites such as chemical plants, refineries, and manufacturing facilities.  They are not a regulatory agency, but their teams of investigators make recommendations to OSHA and EPA, industry groups and the facilities they investigate.

In addition to investigation reports and root cause analyses, CSB issues safety videos on both their website and YouTube that summarize the important findings from their investigations in order to help prevent similar accidents from reoccurring.

Emergency Pressure Relief System Issues

In its investigations, CSB is continuing to find issues with the safety of emergency pressure relief systems.  In several of their investigations these systems were found to be discharging toxic or flammable materials to areas which were not safe for workers or the public.

Emergency pressure relief systems are devices installed on storage tanks, silos, vessels and processing plant equipment to help relieve the excessive pressure caused by fire, process failure, equipment failure or some other change in condition. The pressure relief device is supposed to prevent the equipment it’s installed on from rupturing or exploding.

One of the most well-known accidents involving an emergency pressure relief system was the Union Carbide disaster in Bhopal, India in the 1980s.  A runaway reaction generated high pressure conditions in a storage tank and a methyl isocyanate cloud escaped from the pressure relief system, killing 3,800 people, and injuring or creating long-term illnesses for tens of thousands.

Three Key CSB Suggestions

CSB recommends that rather than discharge into the air or back into the plant, emergency relief systems should discharge to a flare or a scrubber system.

CSB offers three key lessons from its findings:

  1. Follow Existing Good Practice Guidance

Use API 521, Pressure-relieving and Depressuring Systems as a standard guidance. CSB says this document “…addresses many concerns about releasing flammable vapors directly into the atmosphere and generally requires using inherently safer alternatives for toxic release scenarios or when the potential exists for a flammable vapor cloud.”

CSB also recommends documents published by the Center for Chemical Process Safety (CCPS) called Guidelines for Pressure-relief and Effluent Handling Systems and Safe Design and Operation of Process Vents and Emission Control Systems as well as viewing American Institute of Chemical Engineers (AIChE) presentations and courses on Venting and Emergency Relief.

  1. Evaluate Whether the Atmosphere is the Appropriate Discharge Location or if There May Be Safer Alternatives

CSB typically recommends flaring is safer than atmospheric vent stacks when venting flammable vapor into the atmosphere.  Something like flammable hydrocarbons can cause a fire or a vapor cloud explosion when they are vented into the atmosphere.  CSB recognizes flaring is safer, but does allow for venting into the atmosphere in special cases, especially when that venting will not put workers or the public at risk.

  1. Ensure Hazardous Chemicals Vented Into the Atmosphere Discharge to a Safe Location

Where are the discharge points on your emergency pressure relief systems?  Are they at areas where they can harm workers within its proximity at ground level or on walkways or platforms?   Are they near building intakes?  If your company is subject to Process Safety Management (PSM) requirements, CSB says the required periodic reviews would be a good time to evaluate these issues as well as other audits or incident investigations.

Read the Report

Find CSB’s report, along with four case studies and their resulting recommendations at https://www.csb.gov/assets/1/6/csb_eprs_alert.pdf.

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The Importance of Water Audits: A Comprehensive Guide

The Importance of Water Audits: A Comprehensive Guide

Mar 29, 2023

What Is a Water Audit?

A water audit is a systematic examination of all aspects related to water use and efficiency in a given facility. It involves measuring, monitoring, and analyzing water use patterns to identify opportunities for improved water efficiency. This term is often used by water auditors, professionals who specialize in conducting these assessments.

The Role of the International Water Association (IWA)

The IWA is a global network of water professionals striving towards a water-wise world. They advocate for effective water management practices, including the need for regular water audits. They emphasize that understanding water usage patterns is key to achieving sustainable water management.

Why Are Water Audits Important?

Water audits are essential tools for commercial and institutional facilities seeking to conserve water and reduce costs. They provide valuable insights into a facility’s water use, helping to identify inefficiencies and opportunities for improvement.

The Role of a Certified Landscape Irrigation Auditor

A certified landscape irrigation auditor is a professional who evaluates irrigation systems to ensure they are operating efficiently. They play a crucial role in the annual water audit, particularly for facilities with extensive landscapes.

Understanding Regional Water Resources Agencies

Regional water resources agencies are responsible for managing and protecting local water resources. They often provide free water audit software to help businesses and organizations conduct their own audits. These tools can be invaluable for entities attempting to improve their water efficiency.

Achieving Water Efficiency through Water Audits

Water audits are a critical step towards achieving water efficiency. By identifying leaks, inefficient appliances, and wasteful behaviors, audits enable facilities to take targeted action to reduce water use.

Landscape Irrigation Water Use

Landscape irrigation can be a significant contributor to a facility’s water use. A basic irrigation schedule, recommended by the Irrigation Association, can help manage landscape irrigation water use effectively.

The Role of Water Utilities

Water utilities are responsible for supplying clean, safe water to the community. They often offer a water loss control program to help customers reduce their water usage and lower their bills.

Digging into Water Audit Data

Water audit data provides a wealth of information about a facility’s water use. This data can reveal patterns and trends, helping to identify areas where water efficiency can be improved.

Understanding the Water Audit Method

The water audit method involves collecting data on water use, analyzing this data, identifying inefficiencies, and recommending improvements. This method can be carried out by a professional water auditor or using free water audit tools provided by water utilities.

The Benefits of a Free Water Audit

Many water utilities offer free water audits to their customers. These audits can provide valuable insights into a facility’s water use and identify opportunities for cost savings.

Managing an Irrigation Project

An irrigation project, such as upgrading an existing system or installing a new one, can significantly impact a facility’s water use. An audit can ensure that the project is designed and implemented with water efficiency in mind.

The Future of Water Audits

As water scarcity becomes an increasingly pressing issue worldwide, the importance of water audits is set to grow. With the support of organizations like the IWA and regional water resources agencies, water audits will continue to play a key role in promoting sustainable water use.

In conclusion, water audits are a vital tool for managing water use effectively. By identifying areas of inefficiency and recommending targeted improvements, they enable facilities to conserve water, reduce costs, and contribute to a more sustainable future.

Need Help?

Our team of experts can help you with whatever compliance issues you may be facing. Whether it is understanding the complexities of a given regulation or recognizing where your company needs to improve, we have the necessary skills and experience to provide assistance. We will take the time to understand your unique needs and develop tailored solutions that address those needs. For facilities looking for help navigating the often perplexing regulatory landscape, contact us today!

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Making Changes to Equipment or Operations? Do You Need a Construction Air Permit?

Making Changes to Equipment or Operations? Do You Need a Construction Air Permit?

Mar 3, 2023

What Are Construction Air Permits and How Do We Determine If We Need One?

Whenever you plan on making changes to equipment or operations, before you ever get started, your company should always determine whether or not you will need to obtain a construction air permit from your state (or local) environmental agency.

Air Permit Regulations

The Clean Air Act sets standards to prevent significant deterioration (PSD) of the air quality for an area.  This is a federal regulation and EPA has the regulatory authority to enforce it, but it can also delegate authority to individual states by approving the state’s plans to enforce these regulations.

Air permits are required any time a company will exceed criteria for six different criteria pollutants (sulfur dioxide, carbon monoxide, particulate matter, lead, nitrous oxides, and ozone (volatile organic compounds)) or from a list of 187 hazardous air pollutants. Permits outline the emission sources at a facility and can include emission limitations, equipment maintenance requirements, and reference applicable Maximum Achievable Control Technology (MACT) standards and New Source Performance Standards (NSPS).

What Kinds of Activities May Need an Air Permit?

Some examples of equipment or processes that may produce emissions that may require an air permit may include:

  • Compressors
  • Paint Booths
  • Degassing Vessels or Lines
  • Engines
  • Generators
  • Ovens
  • Incinerators
  • Boilers

Some activities that may produce emissions to require an air permit may include:

  • Loading/Unloading Operations
  • Material Storage/Transfer
  • Painting
  • Solid Wastes
  • Tank Loading/Unloading
  • Truck Loading/Unloading
  • Valves, Vents, Vessels and Tanks
  • Wastewater Treatment
  • Welding
  • Asphalt Mixing/Rock Crushing

Operating Permits vs. Construction Permits

Air permits required for regular operations are called operating permits.  They are applicable to the entire facility.  There are different types of operating air permits based on whether or not you are located in an EPA area of nonattainment, how you much you will be emitting, and what you’ll be emitting.

Air permits can also be required for specific projects where you’re going to be making changes or additions, and these are called construction permits/approvals.  Even though the word construction is used, you don’t have to technically be doing “construction” activities.  In this instance, it means the process of making any change to an operation.  Once the change has been made, that change then becomes part of the operating permit because it becomes part of the facility operations.

Depending on the state, sometimes operating and construction permits are done at the same time to prevent time loss between making the change and getting the new operation up and running.  Some states do them separately.  Some states require construction permits be incorporated into the facility’s operating permit, and other states will issue combined construction/operating permits.

Construction Permits/Approvals

Except in limited situations, air construction permits must be received BEFORE your construction or change can commence.

Some changes to your facility that could require a construction permit include:

  • Installation of new process equipment;
  • Modification to existing process equipment;
  • Installation of or change in an emission control device;
  • Debottlenecking of a process that allows for increased production; or,
  • Increases to throughput or operating hours (if currently limited by an operating permit).

Determining If You Need a Construction Air Permit

As with operating permits, for a construction air permit one of the first things you’ll need to do is determine how this change will affect your Potential to Emit (PTE).  This is the maximum design capacity of a stationary source to emit a pollutant under its physical and operational design.  Calculate the PTE for each pollutant associated with this source.  There are several different ways to do this calculation and your state may have a preference on which one you use to determine your PTE.

Once the PTE for the project or modification has been calculated, compare it to the construction permitting thresholds.  Please note that in some cases, you may still need to have a construction air permit even if potential emissions are lower than the construction approval thresholds.  For examples, what type of equipment it is or what type of process it is may affect its status.  Check your state’s rules on what their guidelines are.

Obtaining the Permit

If your calculations tell you the project requires an air construction permit, the customary application must be submitted for approval.  If a project is going to make such a difference that it will now trigger Major Source or Major Modification thresholds, you may need to obtain a Federal Air Permit.  This is a lengthy application, and approval can take quite a long time, from several months to well over a year or two, depending on your state and the workload.  So, it’s very, very important you try to do this well ahead of the time you plan on making the change.

If you already have an operating permit, be aware that your change that you are looking at getting permitted under the construction permit may cause changes to your operating permit at the same time.  Know exactly what the conditions of your operating permit are and see how these changes will affect it so that if you are in a state which does operating and construction permits separately, you can get started on making changes to your operating permit now so that you can operate the results of the construction.

Some states have a streamlined construction permit application process for certain equipment such as emergency generators or boilers.  These applications are short and sweet and typically receive agency approval quickly.

If the project meets the exemption from air construction permitting, retain all documentation for your files.  Even if exempt from permitting, state or federal regulations may have requirements for the source, and you still may need to complete some state paperwork.

With all air permits, both construction and operating permits, once you have turned in your application, be prepared to wait.  The state agency will check for the completeness of your application and may have questions.  Once any issues have been resolved, you should receive a draft of your permit to review and comment on. If it’s not in your state’s policy to send a draft, ask for one, especially if it’s a combined operating/construction permit.

Make sure you read this draft!  You will be held to what this permit says.  Make sure everything about the permit is correct, including any equipment details, inconsistencies, unclear language, typos, etc.  Remove or clarify any ambiguities to make the conditions as broad as possible. Any errors could cause you issues later when being inspected, leading to an inspector thinking you are doing something differently than what’s allowed in the permit.

Once the draft has been approved, there may be a public notice period depending on state policy, and then after that you should receive your permit.

Please note, your construction permit could take several months to be approved, so make sure you plan accordingly.  And also remember…construction permits must be obtained BEFORE construction can be started.

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What is a Phase II Environmental Site Assessment?

What is a Phase II Environmental Site Assessment?

Feb 17, 2023

What is a Phase II?

A Phase II Environmental Site Assessment (ESA) is an in-depth procedure conducted by a environmental professional to confirm the presence or absence of suspected contaminants.

This assessment typically follows a Phase I ESA and involves more intensive methods such as soil, groundwater, or building materials sampling and laboratory analysis.

Phase II ESAs are essential when dealing with properties that may have been affected by hazardous substances. The environmental site assessment process provide a detailed understanding of the environmental conditions at a site and act as a critical tool in managing potential liabilities associated with contamination. Conducting an environmental site assessment is a staple of a companies environmental due diligence.

What’s the Difference Between a Phase I Environmental Site Assessment and Phase II Environmental Site Assessment?

While both assessments aim to evaluate potential environmental risks associated with a property, their methodologies differ significantly.

Phase I environmental site assessments are essentially a preliminary study. It involves a detailed review of historical records and a visual inspection of the property to identify potential environmental risks. This phase does not involve any physical testing or sampling.

Instead, it focuses on identifying ‘Recognized Environmental Conditions’ (RECs) that indicate the possible presence of contamination on the site.

On the other hand, a Phase II assessment is a more detailed and hands-on investigation. It is triggered when RECs are identified during the Phase I assessment. Phase II involves actual sampling and testing of soil, groundwater, or building materials to confirm if suspected contaminants exist at concentrations above regulatory limits.

When Do I Need a Limited Phase II ESA?

A Limited Phase II ESA is often required when the Phase I ESA identifies potential environmental risks, but the suspected contamination is localized to specific areas of the site.

This more focused assessment is less extensive — and thus less costly — than a full Phase II ESA but still provides valuable insight into potential environmental liabilities. It involves targeted sampling and analysis based on the findings from the Phase I ESA.

Who Pays For A Phase 2 ESA?

Typically, the party who stands to benefit from the information generated by a Phase II ESA is responsible for its cost.

This could be a prospective buyer who wants to ensure they are not acquiring contaminated property, a current property owner seeking to understand their liability, or a lender requiring assurance on the environmental status of a property before approving a loan.

In some cases, the cost may also be negotiated between the buyer and seller as part of the property transaction process.

How Long Does a Phase 2 ESA Take?

The duration of a Phase 2 ESA can vary depending on several factors. These include the size and complexity of the site, the number of samples taken, and laboratory turnaround times for sample analysis. On average, a Phase II ESA can take anywhere from a few weeks to a couple of months to complete.

How Much Does a Phase 2 Environmental Study Cost?

The cost of a Phase 2 ESA varies widely based on the scope of work required. Factors influencing the cost include the size and complexity of the site, the type and number of samples, and the analytical methods used. It can range from a few thousand dollars for a Limited Phase II ESA to tens of thousands for a more complex site.

What Is The Final Goal of a Phase 2 Assessment?

The ultimate goal of a Phase 2 Assessment is to provide a clear understanding of the environmental conditions at a site. The findings from a Phase II ESA can significantly impact property transactions, lending decisions, and redevelopment plans.

If contamination is confirmed, it may necessitate remediation under local, state, or federal regulations. By identifying these issues early, businesses can proactively manage potential liabilities and avoid unexpected costs and delays.

Conclusion:

In conclusion, a Phase II Environmental Site Assessment is a critical tool in managing environmental risks. This environmental assessment provides a detailed understanding of the recognized environmental condition at a site, helping stakeholders make informed decisions and potentially avoid significant future liabilities.

Although the process may seem daunting, it is a crucial step towards ensuring the safe and responsible use of land.

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Our team of experts can help you with whatever compliance issues you may be facing. Whether it is understanding the complexities of a given regulation or recognizing where your company needs to improve, we have the necessary skills and experience to provide assistance.

We will take the time to understand your unique needs and develop tailored solutions that address those needs. For facilites looking for help navigating the often perplexing regulatory landscape, contact us today!

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EPCRA Tier II: Does the March 1 Deadline Apply to Your Facility?

EPCRA Tier II: Does the March 1 Deadline Apply to Your Facility?

Feb 15, 2023

The Emergency Planning and Community Right to Know Act (EPCRA) requires facilities to report emergency and hazardous chemical information each year to their state and local emergency response officials and local fire departments. This is a federal requirement, but each state has its own nuances in method of submittal, what’s required with the submission and who to send it to. For reporting, EPCRA has a Tier I form and a Tier II form. The Tier II has all of the information Tier I does, but with more detail, so many states just require the more complete Tier II form.

Does This Apply to My Facility?

First, all chemicals you’re required to keep a Safety Data Sheet (SDS) for per OSHA requirements are subject to reporting. Next, determine if the quantities on-site at any one time last year met the threshholds for reporting.

Extremely Hazardous Substances listed in 40 CFR part 355 Appendix A and Appendix B, the reporting quantity is 500 pounds or the amount of the Threshold Planning Quantity (TPQ), (whichever is lower). Gasoline and diesel fuel at retail gas stations have their own individual requirements. For all other hazardous chemicals, the threshold is 10,000 pounds.

There are a few exclusions per EPCRA for food, food additives, drugs, cosmetics, substances for general/household purposes for use by the general public, fertilizer sold to farmers, and substances used by research labs and hospitals.

Information Collected

Each state has its own requirements, but the information reported is very similar. Some examples of information you’ll need to gather include:

  • SDS for Each Chemical
  • Facility Information
  • Emergency Contacts and Contacts Knowledgeable of Tier II Information
  • Physical and Health Hazards
  • Chemical Descriptions
  • Maximum Amount Present on any Single Day During Reporting Period
  • Average Daily Amounts (Weights)
  • Number of Days Onsite
  • Storage Types, Conditions and Locations

Reporting

Each state varies on how the information is reported then given to emergency officials. Some states require electronic reporting, others may require you to send it directly to your state emergency response commission, your local emergency response commission and the fire department with jurisdiction over your facility. Check out your state requirements here. Reporting is due March 1.

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Mar. 1 will be here soon — Let iSi take care of this requirement for you!

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Mar. 1 will be here soon — Let iSi take care of this requirement for you!

Get Help Here

The Emergency Planning and Community Right to Know Act (EPCRA) requires facilities to report emergency and hazardous chemical information each year to their state and local emergency response officials and local fire departments. This is a federal requirement, but each state has its own nuances in method of submittal, what’s required with the submission and who to send it to. For reporting, EPCRA has a Tier I form and a Tier II form. The Tier II has all of the information Tier I does, but with more detail, so many states just require the more complete Tier II form.

Does This Apply to My Facility?

First, all chemicals you’re required to keep a Safety Data Sheet (SDS) for per OSHA requirements are subject to reporting. Next, determine if the quantities on-site at any one time last year met the threshholds for reporting.

Extremely Hazardous Substances listed in 40 CFR part 355 Appendix A and Appendix B, the reporting quantity is 500 pounds or the amount of the Threshold Planning Quantity (TPQ), (whichever is lower). Gasoline and diesel fuel at retail gas stations have their own individual requirements. For all other hazardous chemicals, the threshold is 10,000 pounds.

There are a few exclusions per EPCRA for food, food additives, drugs, cosmetics, substances for general/household purposes for use by the general public, fertilizer sold to farmers, and substances used by research labs and hospitals.

Information Collected

Each state has its own requirements, but the information reported is very similar. Some examples of information you’ll need to gather include:

  • SDS for Each Chemical
  • Facility Information
  • Emergency Contacts and Contacts Knowledgeable of Tier II Information
  • Physical and Health Hazards
  • Chemical Descriptions
  • Maximum Amount Present on any Single Day During Reporting Period
  • Average Daily Amounts (Weights)
  • Number of Days Onsite
  • Storage Types, Conditions and Locations

Reporting

Each state varies on how the information is reported then given to emergency officials. Some states require electronic reporting, others may require you to send it directly to your state emergency response commission, your local emergency response commission and the fire department with jurisdiction over your facility. Check out your state requirements here. Reporting is due March 1.

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iSi can help you determine your applicability, what your state requires and then help you complete the Tier II reporting elements. Contact us today for a pricing quote!

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EPA Proposes Changes to Air Permitting Regulations for New Sources

EPA Proposes Changes to Air Permitting Regulations for New Sources

Dec 15, 2022

Companies with operations subject to the Clean Air Act are required to submit their plans for any operational or physical changes before they occur to see if they’ll have a significant affect on air quality.  This program is called the New Source Review preconstruction permitting program, or NSR program.  EPA is making some changes in the way fugitive emissions are figured into the equation to determine if the changes to existing sources will be considered a major modification to the company’s air permit.

 

The NSR Program

EPA’s NSR program wants to make sure that a company’s changes will not significantly affect air quality of the area.  In the U.S., there are cities and regions that have air quality levels that are above EPA’s National Ambient Air Quality Standards. These areas are called “non attainment” areas and industries in those areas have additional rules, regulations and restrictions they need to follow as a result.  In other cities and regions that are still below the national standards, EPA wants to make sure a company’s changes don’t significantly deteriorate the area’s compliance so that they can stay below non attainment.  This program is called the Prevention of Significant Deterioration, or PSD program.

The NSR program looks to see if your new operations will become a new major source of air pollution, or if any changes to your current major source permit would be considered a major modification, depending on certain thresholds.

 

Fugitive Emissions

When making this determination, EPA counts fugitive and stack (non-fugitive) emissions.  A fugitive emission is one that could not reasonably pass through a stack, chimney, vent, or similar opening.

Historically, for new sources to become new major sources, only certain type of sources belonging to a specific list would have to count fugitive emissions toward the threshold.

Existing sources would have to count both fugitive and non-fugitive (stack) emissions.  However, in 2008, EPA finalized a rule for existing sources that would also allow them to only count fugitive emissions only for certain types of major sources belonging to specific categories.

 

The Proposed Changes

The specific categories of sources that had to count fugitive emissions were petroleum refineries, large fossil fuel-fired steam electric plants, and Portland cement manufacturers.  Everyone else was not required to include fugitive emissions.

However, EPA wants to repeal that 2008 rule for major modifications.  Now, all existing major sources would need to count fugitive emissions toward the major modification thresholds.

Anytime a company’s changes are considered a major modification, they need to obtain a major NSR permit before moving forward with construction. The permit will require emission control measure to ensure that changes won’t degrade air quality.

Another change that EPA is proposing is to remove a provision established in 1980 that exempts certain stationary sources from substantive major NSR requirements if the only reason the change is considered a “major modification’ is because fugitive emissions are included.

 

Upcoming Changes at Your Facility? What’s Your Air Compliance Status?

Are you considering a major change to your operations or equipment that will affect your air compliance status?  Do you need help with construction air permitting or making determinations on what your air quality compliance requirements are?  Let our team of air permitting experts assist you!  Contact us today!

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EPA Issues Changes to 6H NESHAP for Paint Stripping & Surface Coating

EPA Issues Changes to 6H NESHAP for Paint Stripping & Surface Coating

Dec 1, 2022

EPA has issued Final Rule updates to 40 CFR Part 63, subpart HHHHHH, the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources.  This NESHAP standard applies to companies coating miscellaneous parts/products made of metal, plastic or a combination, anyone stripping paint using methylene chloride, or conducting motor vehicle/mobile equipment refinishing.

EPA issued the changes as part of its technology review.  They didn’t find any new developments in practices, processes or controls that warranted changing existing rules, but they did decide to take the opportunity to update and clarify some of the items in the current requirements.

Here is a summary of what has changed in the regulation:

Electronic Reporting

Rather than mailing reports to EPA, you will now be required to be submit electronically through the CEDRI/CDX platform.  This includes initial notifications, notifications of compliance status changes, annual notification of changes reports and the report required in 40 CFR 63.11176(b).

HAP Content

EPA updated the definition of a “target HAP containing coating” to clarify that compliance is based on the hazardous air pollutant (HAP) content of the coating applied to the part, not the content purchased.

Spray Gun Cups and Liners

For spray guns with disposable cap liners, EPA amended “spray-applied coating operations” to clarify that the allowance to use spray guns outside of a spray booth is based on the volume of the spray gun cup liner, not volume of the cup itself.  They also clarified that repeatedly refilling and reusing the 3.0 fl. oz. cup or cup liner, and/or using multiple liners for a single spray-applied coating operation will be considered trying to circumvent the regulation and you can be fined for this.

Exemptions Became Easier

If motor vehicle/mobile equipment spray coating operations don’t spray apply coatings that contain the target HAP, rather than the current petition for exemption process, the rule now allows companies to submit notifications to the Administrator.  This process is meant to be simplified and easier.  All records to support the notification shall still be kept as a backup to support the notification, but those records don’t need to be sent to the administrator.

Military Equipment: Tanks and Submarines

The NESHAP no longer applies to surface coating or paint stripping on tanks and submarines when that work is conducted onsite at military installations, NASA, or at the National Nuclear Security Administration.  It also doesn’t apply when conducted offsite where military munitions or equipment are manufactured by or for the Armed Forces and that equipment is directly and exclusively used for the purposes of transporting military munitions.

OSHA Carcinogen References

EPA removed references to OSHA’s carcinogens because OSHA no longer spells out what those are.  Instead, EPA will be putting in their own list.  These will include target HAPs that must be counted if they’re present at 0.1% by mass or greater.  All other HAPs will be counted if present at 1.0% or greater by mass.

No Non-HAP Solvents

The term “Non-HAP solvent” will be removed because there’s no requirement in the standard to use them and there is no other place where this is used.

Filter Test Method

EPA updated the spray booth filter test method to the most recent ASHRAE method, ANSI/ASHRAE Standard 52.2-2017 Method of Testing General Ventilation Air-Cleaning Devices for Removal Efficiency by Particle Size.  The standard also now includes a reference to EPA Method 319-Determination of Filtration Efficiency for Paint Overspray Arrestors as an alternative method.  EPA Method 319 is the same one referenced in the NESHAP for Aerospace Manufacturing and Rework to test paint spray booth filters for hexavalent chromium emissions.

For more information about changes to the rule, you can find the final rule in its entirety here.

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The Comprehensive Guide to an Environmental Audit Checklist

The Comprehensive Guide to an Environmental Audit Checklist

Nov 6, 2022

In an era where environmental consciousness is at the forefront, businesses must ensure they meet and exceed environmental compliance norms. As leaders in Environmental, Health, and Safety (EHS) services, iSi is committed to guiding you through the intricacies of environmental compliance.

Decoding Environmental Compliance

Environmental compliance refers to the adherence to environmental laws, environmental regulations, standards, and other requirements such as site permits to operate. Non-compliance can lead to severe penalties, including substantial fines and potential operational shutdowns.

The Importance of Environmental Audit Reports

Environmental audit reports are essential tools for assessing a company’s environmental performance. These reports provide a comprehensive picture of how well a business adheres to environmental rules, helping identify possible environmental issues and areas for improvement.

The Role of an Environmental Compliance Audit

An environmental compliance audit evaluates a company’s adherence to environmental laws and regulations. It assesses the effectiveness of the company’s environmental management systems, providing a detailed overview of the company’s environmental impact.

Unpacking the Audit Checklist

Creating an audit checklist for an environmental audit can be daunting due to the extensive range of factors involved. However, our expertise allows us to distill this process into key areas that should be your primary focus:

1. Regulatory Requirements: Ensure your business is aware of and complies with all relevant local, state, and federal environmental laws and regulations. This includes rules related to air quality, water quality, waste management, and hazardous materials.

2. Environmental Permits: Verify that all necessary environmentally focused permits are current and that operations are within permit conditions. This could include discharge permits, emission permits, or waste disposal permits.

3. Waste Management: Review waste management practices to ensure hazardous and non-hazardous waste is correctly identified, stored, transported, and disposed of. This is particularly important under acts like the Toxic Substances Control Act.

4. Emissions Control: Check that all emission control systems are functioning correctly and comply with required standards.

5. Record Keeping: Ensure all necessary records, reports, and documentation related to environmental compliance, including employee training records, are properly maintained and readily accessible.

6. Employee Training: Confirm that all employees have received appropriate training regarding environmental compliance responsibilities.

7. Emergency Preparedness: Evaluate your company’s preparedness for environmental emergencies and ensure there is an emergency response plan in place.

The Depth of Functional Environmental Audits

Functional environmental audits assess the effectiveness of a company’s environmental management system. These audits evaluate various aspects, such as air quality monitoring, wastewater management, materials management, and compliance monitoring.

Understanding Environmental Laws

Environmental laws are designed to mitigate environmental harm by regulating activities that impact the environment. They cover a broad range of areas, from air and water quality to waste disposal and hazardous materials.

The Role of Regulatory Agencies

Regulatory agencies enforce these laws and regulations. They play a crucial role in issuing environmental permits, monitoring compliance, and taking enforcement action when necessary.

The Impact of a Company’s Environmental Performance

A company’s environmental performance has significant implications for its reputation and bottom line. High environmental performance can lead to cost savings, improved stakeholder relations, and enhanced market opportunities.

The Importance of a Detailed Regulatory Checklist

A detailed regulatory checklist is an invaluable tool for ensuring compliance with environmental rules and regulations. This checklist provides a structured approach to identifying potential compliance issues and addressing them effectively.

Final Thoughts on Environmental Compliance

In conclusion, an environmental compliance audit is not just a formality but a vital part of your business’s sustainability strategy. With this comprehensive checklist and iSi by your side, you can navigate the complexities of environmental compliance with confidence and ease.

At iSi, our focus is not just on helping businesses meet environmental standards but also on fostering a culture of sustainability and responsibility. We believe that environmental compliance is not just a box-ticking exercise but a commitment to our planet and future generations.

Choose iSi for your environmental auditing needs, and let’s work together to create a safer, healthier, and more sustainable world. Contact us today to learn how we can help you achieve EHS excellence.

How Can We Help? Ask a Question or Request Info or Pricing

Do you need an idea of where you stand with EPA or OSHA regulations?  Do you need full-time or temporary personnel to manage the day-to-day compliance tasks?  Would your employees benefit from onsite environmental training?  Our team of environmental consultants, safety consultants and industrial hygienists would love to help. Call (316) 264-7050 today!

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Mining Testing

Mining Testing

Oct 27, 2022

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What is it?

Mining testing is a process that helps evaluate the safety, productivity, and environmental impact of mining operations, mining services, and the mine site. It involves collecting data from various sources such as geological surveys, graphical analysis, borehole drilling tests, hydrogeological studies, geophysical surveys and laboratory testing to ensure the quality and sustainability of mining projects.

This type of testing helps identify potential risks before proceeding with large-scale mining operations, helping to ensure that the safety of miners and environment is protected in the mining industry. Additionally, it also helps identify resources that are economically viable for extraction.

Mining testing is an essential part of any successful mining venture and is carried out by experienced professionals with specialized knowledge in order to maximize success. This testing should be used in any mine planning as any good mining engineering professional would advise.

What are the different types of mining tests?

Mining tests are used to assess potential mining sites and the quality of ore they contain. These tests can identify if a particular rock or mineral is economically viable for extraction, as well as provide information about the environmental impact of a particular mining operation.

There are several types of tests commonly used in the industry including geophysical surveys, chemical analyses, drill core sampling, and exploratory mining. Geophysical surveys use various techniques such as magnetometers, gravimeters, and seismic reflection to identify subsurface structures that may contain economically valuable ore. Chemical analyses involve taking samples from the site for laboratory analysis to determine the mineral content of an ore body.

Drill core sampling involves taking cylindrical samples of rock from different depths in order to determine the grade of ore as well as to determine overall mineral composition and structure. Exploratory mining or underground mining proposed by exploration companies involves digging trial pits or tunnels in order to gain a better understanding of the deposits present at a particular site. Each of these tests can provide important information for successful mining operations, allowing companies to make decisions that will maximize their profits while minimizing environmental impacts.

How do you test for mineral content?

Mineral content in water is tested using a variety of methods. A common method is to use colorimetry, which involves measuring the amount of light absorbed by different chemical compounds in the sample being tested. Another way to test mineral content is through ion-selective electrodes, which measure the electrical potential between two points and can be used to identify certain ions or minerals present in the sample.

X-ray fluorescence spectroscopy is also used to detect and quantify minerals in water samples, as it looks for the presence of specific chemical elements. Finally, Inductively Coupled Plasma Mass Spectrometry (ICP-MS) can be used to measure trace levels of minerals in a sample by analyzing the frequencies emitted by different particles.

What do MSHA (Mine Safety & Health Administration) inspectors look for?

MSHA inspectors are responsible for ensuring the safety and health of miners in the workplace. They look for a variety of conditions to ensure miners are following safety regulations, such as checking ventilation systems, guarding against hazardous machinery, inspecting electrical equipment, and monitoring fire risks. They also take into account worker practices like wearing personal protective equipment, using approved methods for lifting heavy objects, and following all regulations and guidance. This work practices should be spearheaded by company management which provides extensive training for employees.

Furthermore, MSHA inspectors review records of workplace illnesses and injuries to identify underlying safety issues that need to be addressed. Finally, they observe work areas to make sure miners are aware of hazards and have the necessary tools and equipment to do their jobs safely. MSHA inspectors play an important role in safeguarding the health and safety of miners.

What does a mining consultant do?

A mining consultant, also known as a mineral engineer or natural resources specialist, is responsible for helping companies and organizations extract the maximum value from their mining operations. They work closely with clients to assess and analyze geological data in order to develop cost-effective production plans that take into account environmental protection decisions. Mining consultants may also be tasked with developing mine reclamation plans, assisting with feasibility studies, monitoring safety and compliance issues, and providing expert testimony in legal proceedings.

In addition, they may be called upon to provide environmental consulting services for mining projects, advise on policy development related to the industry, and conduct research on new technologies and processes that could improve extraction practices. As such, mining consultants play an important role in helping organizations maximize their returns while promoting sustainable mining practices.

Need Help?

Our team of experts can help you with whatever compliance issues you may be facing. Whether it is understanding the complexities of a given regulation or recognizing where your company needs to improve, we have the necessary skills and experience to provide assistance. We will take the time to understand your unique needs and develop tailored solutions that address those needs. For facilites looking for help navigating the often perplexing regulatory landscape, contact us today!

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SMETA Audits

SMETA Audits

Sep 20, 2022

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SMETA AUDIT: What you need to know

What is a Smeta audit?

SMETA or Sedex Members Ethical Trade Audit is the leading global ethical audit and assurance methodology that helps companies to assess their suppliers’ performance against a set of criteria.

It covers labor, health & safety, environmental and ethics standards which are all important for responsible business practices. SMETA audits provide companies with an objective evaluation of supplier operations and highlight any areas for improvement. This helps

What are the 4 pillars of Smeta audit?

  1. Labor Standards

  2. Health and Safety

  3. Business Ethics

  4. Environmental Assessment

The 4-pillar SMETA audit, developed by the Sedex organization, is a globally accepted audit system used to assess a company’s ethical and sustainability practices. It requires organizations to adopt business practices beyond traditional labor standards in order to ensure that their operations are socially responsible.

The two mandatory pillars of the audit are Labor Standards and Health & Safety. Two additional pillars – Business Ethics and Environment – were introduced to further strengthen the social responsibility aspect of the audit.

Business Ethics encompasses areas such as anti-corruption, bribery, data protection, human trafficking prevention, gifts & entertainment and whistleblowing policy. These measures protect companies against unethical practices which can have serious reputational consequences for an organization if left unchecked. Ethical trading initiative and responsible business practice for all company’s is a necessity.

The Environmental pillar focuses on environmental management, renewable energy, efficient use of resources and waste minimization. Companies must demonstrate that they are taking all possible steps to minimize their impact on the environment and meet the expectations of society such as implementing sustainable business practices.

The 4-pillar SMETA audit is an effective way for companies to review their current practices around labor standards, health & safety, business ethics and environment. It provides a comprehensive view into a company’s social responsibility policies ensuring that operations are ethical, responsible and sustainable in the long run.

By completing this audit successfully, organizations can ensure that their products or services adhere to high levels of quality while also meeting sustainability benchmarks. This helps them build trust with partners, customers and other stakeholders while demonstrating corporate social responsibility.

How long is a Smeta audit valid for?

The SMETA audit report is a valuable tool for businesses to assess their ethical practices and ensure that their performance meets the highest standards. However, the validity of the audit report can vary depending on what timeframe the client decides upon.

Most clients opt for an annual audit cycle and set one year as the period of validity for the SMETA audit report.

How do I get a SMETA audit?

If you’re looking to complete a SMETA audit, the first step is registering and having an active account on the Sedex platform. With the right membership, your business can easily access the resources needed to successfully complete a SMETA audit.

What is the difference between Smeta audits and Sedex?

  1. Sedex is the name of the organization

  2. SMETA is the name of an audit methodology

Sedex’s SMETA audit methodology is widely regarded as the gold standard in ethical supply chain auditing. It is used by Sedex members and their suppliers to help them identify areas for improvement and ensure compliance with local laws, global standards, and corporate responsibility policies.

The audit consists of four sections (Labour Standards; Health & Safety; Environment; Business Ethics) that together provide a comprehensive view of supplier operations. Through SMETA audits, companies can identify and address potential risks in their supply chainsa as well as global supply chains quickly and efficiently.

By addressing any issues they find in their audits, companies can demonstrate commitment to responsible sourcing practices and mitigate business risk.

SMETA audits are conducted on-site by experienced auditors who assess the performance of suppliers in each of the four sections. During the audit, auditors review documents, interview staff, conduct physical inspections, and observe work practices to provide a comprehensive view of supplier operations. After the audit is complete, Sedex will provide a report that summarizes the findings and recommendations for improvement.

Who can conduct Smeta audit?

A SMETA audit will be conducted by an independent third-party auditor. The auditor will analyze the company’s management systems and practices, to ensure that they adhere to the ETI Base Code and local laws. The auditors will review internal policies, management processes, employee training records, and other documents related to labor rights and standards.

In addition, the auditor will observe activities in the workplace such as working hours, working conditions, fire safety regulations, payment of wages, etc., in order to identify any areas of potential non-compliance with ethical trading standards.

After the audit is complete, a report is generated which includes an assessment of compliance with ETI Base Code requirements. Companies who have passed an independent third-party audit typically can demonstrate that their workforce is protected under international labor rights and standards. This provides a degree of assurance to customers and other stakeholders that the company is committed to ethical trading practices.

The audit process helps companies identify areas for improvement, as well as provides an opportunity to address any malpractices that may exist in their supply chain as well as the global supply chain. It also ensures that companies are held accountable for their labor and work standards, helping them build trust with stakeholders and create a positive public image for the business. Furthermore, the successful completion of a audit can open up new opportunities for companies looking to do business abroad by demonstrating compliance with international labor rights and standards.

Conclusion:

SMETA audits, developed by Sedex Global, have become one of the most widely accepted ethical audit methods in the world. It is a comprehensive auditing system that provides an internationally recognized standard for assessing working practices within your supply chain. SMETA is based on four pillars: labor standards (including human rights), health and safety, environment, and business ethics.

The aim of this audit is to ensure compliance with any applicable laws and regulations as well as industry-accepted best practice standards including those related to CSR performance and sustainability initiatives. The audit helps you identify any potential risks or areas where improvement can be made in order to meet these standards and stay compliant with laws or regulations.

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Waste Disposal Facility Audit Checklist

Waste Disposal Facility Audit Checklist

Sep 10, 2022

What is a waste audit?

There are two types of audits: manual and automated.

A waste audit can be conducted in a variety of ways, depending on the organization and its goals. Generally, there are two types of audits: manual and automated. Manual waste audits involve sorting through garbage bags or dumpsters to determine what is being thrown away. Automated audits use sensors or other technology to track the types and quantities of waste that an organization produces.

The resulting data from waste audits can be used to develop a better understanding of the organization’s waste stream and how it can be improved. The data can also help organizations make informed decisions about their purchasing practices, lead to more efficient processes and identify cost-saving opportunities.

How do you plan a waste audit in an organization?

A waste audit is an analysis of a company’s waste stream where you inspect waste management and then implement waste management protocols. It gives insight into the types and amounts of materials that are being sent to landfill and helps inform strategies to reduce, reuse, and recycle more effectively.

What are the steps involved in a waste audit?

To plan a successful waste audit in an organization, there are several steps that should be added to your waste audit checklist:

1. Select your team and plan a date for the waste audit.
2. Gather your equipment.
3. Go through the garbage!
4. Calculate your diversion rate.
5. Communicate your results.

What is included in a waste audit?

Waste audits are useful for many reasons. They can provide facility managers and other stakeholders with important insights into the effectiveness of their current waste management practices and how they might be improved.

Waste audits can also help identify areas where more resources should be devoted to better manage waste, or where additional training or education is needed. By understanding the composition and volume of the waste generated, organizations can better understand how to reduce, reuse and recycle more efficiently and effectively.

Additionally, detailed audits can provide information about potential safety and health hazards within a facility’s regular waste stream.

What are the 7 principles of solid waste management?

The following are the seven principles that will effectively explain solid waste management:

  • Rethink
  • Refuse
  • Reduce
  • Reuse & recycle
  • Repurpose
  • Repair
  • Compost
  • Conclusion

Solid Waste Management is an important tool to reducing our environmental impact. By adding the 7 principles to the solid waste management checklist, we can begin to make a positive difference in the amount of waste generated and disposed of into the environment.

Rethinking how we purchase and use products, refusing those items that are not necessary, reducing the total amount of waste going into the environment, reusing and recycling items that can be either repurposed or repaired, and composting rather than throwing organic waste away are all effective methods of reducing our environmental impact without creating more waste.

By making small changes in our everyday lives, we can have a large impact on the amount of waste going into the environment. The way households and company disposes of waste will significantly aid in the improvement of the communities we live in as well as limit unnecessary waste in landfills.

What are the four criteria that the EPA uses to classify hazardous waste?

EPA’s (Environmental Protection Agency) regulations in the Code of Federal Regulations (40 CFR) identify four hazardous waste characteristic properties: ignitability, corrosivity, reactivity, or toxicity (see 40 CFR 261.21- 261.24).

As part of EPA compliance, company key members, facilities teams, and site management should identify, collect, and document all hazardous waste that is in their facility. Regular site visits and inspections helps determine is the hazardous waste management protocols are properly enforced and in good condition.

Steps following an waste disposal facility audit:

1. Determine whether the waste containers size and pickup frequency still match your needs. If your trash output changed, a different size or number of pickups could cost you less money.
2. Add recycling service to your plan. If you don’t have recycling bins as part of your waste removal plan, consider add it.
3. Set a goal for increasing your recycled waste rate.
4. Create recycling guidelines for meeting that goal and share them with your staff.
5. Set a goal for reducing the amount of waste in your largest categories.
6. Determine the steps to meet that goal and let your staff know. Implementation is key.
7. Identify any items you can reuse. For example, can you repair or recycle your electronics instead of purchasing new ones? Can you repurpose any of your packaging materials?
8. Decide on a timeline for meeting your recycling and reduction goals. One or two years usually makes sense. Plan to conduct another waste audit at that time to see if you met your goals.

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Environmental Protection Agency (EPA) Audit Policy

Environmental Protection Agency (EPA) Audit Policy

Sep 4, 2022

United States Environmental Protection Agency Audit Policy: 101

The Environmental Protection Agency (EPA) is committed to protecting and preserving the environment for all of us, which means ensuring that businesses across the country are following EPA policies. To do this, the agency performs audits on companies in order to ensure compliance with EPA standards.

This includes checking documents and records, sampling chemicals and other materials, evaluating waste management practices, testing equipment, observing production processes, interviewing employees, etc. The goal of each audit is to identify any potential violations or areas of non-compliance with the law.

After completing an audit, the EPA will issue a report outlining its findings and recommendations. Typically, the report will include areas of non-compliance, along with suggestions for corrective action to ensure compliance in those areas. Companies are then required to submit a written response to the audit and provide evidence that steps have been taken to address any issues identified by the EPA.

It is important for companies to be aware of their responsibility and obligation when it comes to environmental protection. The Environmental Protection Agency Audit Policy provides businesses with an opportunity for self-evaluation and proactive strides towards ensuring compliance with all relevant regulations and laws. As such, it is essential that companies remain up-to-date regarding changes in policy or procedure, regularly review their operations and practices, and work diligently to resolve any violations or problems discovered during audits. By doing so, companies can help to ensure a safe and healthy environment for everyone.

An important part of the Environmental Protection Agency Audit Policy includes being able to respond effectively to any audit report issued by the agency. Companies should contact an environmental attorney who is knowledgeable about the requirements outlined in the EPA’s Audit Policy, as well as any applicable state or local laws that may be relevant. In addition, they should develop a detailed plan of action outlining how they intend to resolve any issues identified during an audit and provide evidence of their compliance with all applicable standards. By doing so, businesses can help demonstrate their commitment to protecting the environment and set a positive example for others in their industry.

At the end of the day, businesses have a responsibility to protect the environment and ensure compliance with all applicable laws. Companies who take advantage of this policy are helping to set a positive example for others in their industry and create a healthier future for everyone.

EPA’s Interim Approach to Applying the Audit Policy to New Owners | US EPA

The Environmental Protection Agency (EPA) has developed an Interim Approach to Applying the Audit Policy to New Owners, which provides tailored incentives for new owners of facilities that have been found to be non-compliant with environmental laws prior to acquisition. This approach allows new owners to make a “clean start” by addressing any noncompliance that began before they obtained ownership of the facility.

This Audit Policy incentives include compliance assistance and technical advice, potential reduction in penalties and civil enforcement actions, reimbursement for environmentally beneficial projects, and protection from certain criminal prosecution related to pre-acquisition violations. These incentives are designed to encourage responsible parties at newly acquired facilities to address existing noncompliance issues quickly and effectively through voluntary disclosure or corrective action. By taking advantage of EPA’s Audit Policy incentives, new owners can ensure compliance with environmental statutes and make a fresh start.

What are the benefits of an EPS audit?

The EPA believes that having audits conducted allows organizations to make better-informed actions, optimize performance levels, and ensure sustainable success over the long term..

An EPS audit is a valuable tool for assessing the financial health of an organization. It provides an objective overview of a company’s performance and can help identify areas where improvements or corrective actions may be needed. An EPS audit can also serve as an key preventative measure, providing insight into potential problems before they become catastrophes.

At the same time, it can help to enhance processes and procedures that are already in place by giving management a comprehensive look at their current operations and financial position.

What types of companies are required to perform and environmental audit?

Environmental audit reports are useful to a variety of businesses and industries, local, state and federal government facilities, as well as financial lenders and insurance companies that need to assess environmental performance. Audit reports can be extremely useful for businesses, governments, and financial lenders in understanding the environmental performance of a given facility. They provide detailed information on air emissions, water usage, waste management systems, hazardous materials management practices and storage procedures.

This data is key to ensuring that facilities are meeting regulatory requirements and following industry best practices. Additionally, environmental audit reports may be necessary to meet contractual requirements with customers or other third parties. Finally, financial lenders may use these reports to assess risk associated with a particular project or investment opportunity in order to make informed decisions on whether to lend money or not. Ultimately, environmental audit reports are an essential part of ensuring continual compliance as well as business sustainability.

Who conducts EPA audits?

EPA audits can be conducted by internal auditors, external auditors, and third-party verification organizations.

Internal auditors usually have knowledge and expertise in the specific area being audited, such as environmental protection, energy efficiency or sustainability. External auditors are independent third-party experts who assess and evaluate compliance with EPA ordinances Finally, third party verification organizations provide impartial assessments to verify the effectiveness of an organization’s systems for meeting specific standards. Each type of audit provides its own unique benefits, ensuring that thorough and comprehensive evaluations of facility operations take place.

Through careful review and assessment of procedures, policies and practices, these audits ensure that organizations remain compliant with EPA statutes.

How often are EPA audits required?

Once every three years.

According to the regulations at 40 CFR §§68.58(a) and 68.79(a), owners or operators must certify that they have completed a compliance evaluation of their prevention program every three years in order to ensure that established procedures and practices are adequately maintained and followed.

This process requires the tangible review of all applicable documents, including but not limited to safety protocols, emergency response plans, operating manuals, training records, inspection reports and other relevant documentation.

By completing this certification process on a regular basis, owners or operators can maintain regulatory compliance while helping to protect their employees and fix environmental issues.

What is an environmental audit protocol?

Audit protocols can help facilities evaluate their compliance with environmental laws. They provide guidance on how to develop a plan of action to address any issues and may include information on testing, monitoring, or other practices that are necessary for the facility’s success in meeting environmental requirements.

The protocols should be seen as a supplement to existing permits, statutes and laws; however, these guidelines must still be followed in order to ensure legal compliance. Audit protocols also provide a framework for more efficient evaluation of compliance status, helping facilities save time and resources when assessing their operations.

Why is it necessary for businesses to be sustainable?

Sustainability is becoming increasingly necessary in the business world, as businesses look to adopt greener technologies and practices that benefit both their bottom line and the environment. Sustainable businesses are able to make better use of resources while reducing costs, resulting in greater profits and job security for employees. Smaller businesses can also benefit from sustainable practices, as they often find it difficult to compete with larger organizations due to lower capital investments. An example of such is the The Clean Air Act (CAA) (42 U.S.C. 7401 et seq.) is a comprehensive Federal law that regulates all sources of air emissions.

By adopting more efficient methods and technologies, smaller businesses have the potential to become competitive players in the market. Furthermore, sustainability has a positive impact on employment by ensuring better working conditions for employees; this helps create a more stable economy and helps protect human health. Ultimately, sustainability is essential for creating an economically viable future for businesses, employees, and the environment. By taking strides towards a more sustainable business model, companies can create long-term value for their stakeholders and ensure a brighter future for everyone.

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EHS Software for Healthcare

EHS Software for Healthcare

Aug 21, 2022

What is EHS healthcare?

EHS healthcare is a type of healthcare that focuses on the environmental, health and safety aspects of an individual’s wellbeing. It encompasses a wide range of preventive and proactive approaches to ensure individuals stay healthy both in and out of the workplace. With this type of healthcare, emphasis is placed on a comprehensive risk assessment to identify potential hazards or risks associated with a particular area, such as air quality, water supply, hazardous materials and other environmental factors.

Additionally, the goal of EHS healthcare is to provide educational resources to individuals in order to empower them with knowledge on how best to stay safe and healthy in their environment. Furthermore, EHS healthcare includes activities such as monitoring and responding to health-related incidents, performing safety drills and inspections, providing instruction on health topics, and preparing safety plans. Ultimately, this type of healthcare helps people stay safe and healthy while living in a potentially hazardous environment.

What does EHS stand for?

EHS stands for Environment, Health and Safety. It is an important acronym in the corporate world as it emphasizes the importance of protecting people and the environment through a set of policies, procedures and regulations. EHS promotes a safe workplace for employees and visitors, as well as a healthy environment to live and work in.

These measures help reduce risks associated with potential accidents or incidents. Additionally, they help ensure compliance with local, state and federal regulations, which can help a business avoid costly fines. Ultimately, EHS creates a safer and healthier environment for everyone.

What are the EHS standards?

The EHS (Environment, Health & Safety) standards are guidelines and regulations that aim to ensure the safety and well-being of workers, customers, and communities in a given environment. They cover areas such as hazardous materials management, process safety management, emergency response planning, air pollution control and monitoring, noise control and monitoring, waste management practices, occupational health and safety programs, and much more.

Organizations that follow these standards are able to reduce the risk of accidents, increase productivity, and better protect their workers from potential harm. EHS standards are designed to be comprehensive and flexible; they can be tailored to the needs of any particular organization or industry, making them an effective tool for creating a safe working environment.

What is a the purpose of the EHS management system?

The purpose of an Environmental, Health & Safety (EHS) management system is to ensure that organizations are aware of and comply with relevant environmental, health and safety laws, regulations and standards. It also helps organizations perform risk assessments to identify risks associated with their operations and develop strategies to mitigate those risks.

EHS management systems also provide a framework for the development of policies and procedures that ensure the health and safety of employees and minimizes potential impacts on the environment. Ultimately, EHS management systems help organizations protect their people, assets, and reputation while remaining compliant with relevant laws and regulations.

Furthermore, an effective EHS management system can provide a competitive advantage to organizations by giving them an edge in terms of demonstrating their commitment to environmental responsibility.

Environmental, Health, and Safety for Healthcare

Healthcare facilities must adhere to strict Environmental, Health, and Safety (EHS) standards in order to ensure the safety of their employees, customers, and visitors. These standards include ongoing training for staff on hazardous materials management, waste disposal, air quality monitoring and control, proper handling of medical waste and hazardous chemicals, as well as emergency preparedness protocols.

Facilities are also required to comply with local, state, and federal regulations regarding air quality, water quality, hazardous materials management, indoor air quality, and noise levels. By adhering to EHS standards in healthcare settings, providers are able to protect their patients from potential harm caused by environmental factors.

5 Top Safety Risks in the Pharmaceutical Industry

The pharmaceutical industry is an incredibly complex and regulated environment, and safety risks for workers are abundant. From hazardous chemicals to dangerous manufacturing processes, the risks must be managed vigilantly.

The five top safety risks in the pharmaceutical industry include exposure to hazardous materials, inadequate ventilation systems, improper handling of biohazardous waste, machine-related injuries, and slips or falls on wet surfaces. Exposure to hazardous materials can have serious health consequences for workers, so safety protocols must be strictly followed.

Inadequate ventilation systems can lead to a buildup of dangerous gases and particulate matter, negatively impacting the health of those working in manufacturing plants. Improper handling of biohazardous waste can also pose a serious risk by contaminating environments with disease-causing agents.

What is the Personal Protective Equipment (PPE) in the Pharmaceutical Industry?

Personal Protective Equipment (PPE) in the Pharmaceutical Industry is a set of safety gear used by workers to minimize potential harm and exposure to dangerous materials. PPE can include items such as gloves, masks, respirators, ear plugs, protective clothing and glasses/goggles.

Depending on the type of job or task being performed, different types of PPE may be required. For instance, a worker operating in a sterile environment might be asked to wear a face mask or respirator while handling hazardous chemicals. PPE is designed to both protect the user and patient and reduce the risk of contamination from one job site to another.

By implementing proper safety protocols, such as wearing appropriate protective clothing and equipment, workers can help ensure safe working environments that are free of potential hazards. It is important for employers to provide workers with the proper PPE so they can do their jobs safely and effectively.

Environmental Compliance in Healthcare

Environmental compliance in healthcare is a critical issue. Healthcare organizations must take steps to ensure that their practices and operations are not only legal, but also adhere to sustainability principles. This includes proper handling of hazardous materials, waste management, and energy efficiency. Healthcare facilities must comply with laws governing air, water, and land pollution as well as safety standards for employees and visitors.

Additionally, healthcare organizations must develop and implement an environmental management system to track and manage their environmental performance. By ensuring compliance with environmental regulations, healthcare facilities can contribute to local communities by protecting the environment and public health. Thus, proper environmental compliance is essential for all healthcare organizations.

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Environmental Audits: What You Need to Know

Environmental Audits: What You Need to Know

Aug 17, 2022

Environmental Audits: What you need to know

What is in an environmental audit?

An environmental audit is a tool used to investigate, understand and identify the effects of certain activities on the environment. Depending on the type of audit and the focus of the investigation, different types of environmental audits exist.

Organizations now recognize the importance of environmental matters and accept that their environmental performance will be scrutinized by a wide range of interested parties.

As such, environmental auditing is used to provide insights into an organization’s compliance with environmental regulations, as well as their overall impact on the environment and environmental issues.

Once a thorough review is conducted and completed, the auditors or auditor may help you identify best management practices, implement corrective actions, streamline standard operating procedures and determine environmental programs and environmental plans.

What are the types of environmental audit?

There are three main types of environmental audits: compliance, management, and functional.

Compliance

Compliance audits evaluate a company’s environmental performance and responsibility practices to ensure that they are in line with legal requirements through an environmental assessment. This is usually the most comprehensive and expensive type of audit.

Management

Management audits verify whether a company has met the environmental objectives and performance levels set by management. These audits can help identify areas where improvement is needed such as required permits, materials, employee training records and applicable findings.

Functional

Functional audits focus on the impact of a particular activity, such as wastewater management, air quality monitoring or identifying hazardous waste.

These audits can help pinpoint problems, recommend solutions and identify corrective actions such as regulatory requirements, employees, materials management, if hazardous waste manifests, and more!

What is the role of environmental audit?

The role of environmental audit is to ensure that businesses are compliant with environmental standards and regulations. Environmental auditors assess the environmental operations and procedures for businesses, governments or utility companies.

They are responsible for making sure the environmental standards are being met by the business and detecting existing compliance problems or environmental management deficiencies.

By conducting audits, businesses can learn about their compliance status, identify areas for improvement, and develop action plans to address any deficiencies in their procedures.

Audits also help businesses benchmark their performance against others in their industry and track their progress over time with provided documents and applicable facility safety permits.

What is included in environmental audit?

An environmental audit includes a review of an organization’s compliance with environmental regulations, as well as its impact on the community.

The auditor will also assess the effectiveness of the organization’s environmental management system. Bonus points for identifying and implementing emergency response programs

How do you conduct an environmental audit?

  1. Brainstorm and develop a plan.
  2. Come up with some questions and checklists pre-audit.
  3. Review company background information and documents.
  4. Review operational documents.
  5. Conduct initial site visit and site inspection.
  6. Identify environmental requirements an compliance needs.
  7. Develop on site questionnaire and site checklists.
  8. Provide documents addressing site issues.
  9. Review assessment, inspection reports and sampling data.
  10. Arrange new management practices.
  11. Implement new environmental management systems and a management tool.

When is an Environmental Audit Necessary?

Environmental audits are necessary when there is a possibility that pollution is being generated by any industrial facilities.

The purpose of the audit is to control pollution, address hazardous waste or raw materials and improve product safety at the facility.

Environmental audits also help prevent and reduce chemical waste. In addition, environmental audit reports provide performance reviews of industrial working facilities and their possible impact on the surroundings.

This portion of the report will include an update and evaluation on current facility operations and facility procedures as well as pinpointing site issues and if the auditor has a concern about facility safety.

How do you implement and maintain environmental audit reports in your facility?

Your company or organization will have many documents from the site visit at your disposal. It may seem difficult to determine where to start especially with what feels like huge checklists but your audit will give you a suggestion on where to start from their assessment.

Organization is key to implementing new site management and new scope of work. It is important for companies to understand that it is important for these issues to be addressed and undertaken as soon as possible.

Conclusion

It is true that a concern or two will arise after this process is complete, however you will be able to contact your auditor and discuss any issues you may have with the assessment, facilities, materials, chemicals, tests, findings, regulations and more. A good audit should provide contact details and will be your best friend before and after the process.

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ISO 14001 Checklist

ISO 14001 Checklist

Aug 11, 2022

 

What is Environmental Management System (EMS) auditing?

An Environmental Management System (EMS) audit is the process of assessing an organization’s compliance with ISO 14001:2015, the international standard for environmental management systems.

The audit assesses whether the organization has proper procedures in place to manage its environmental responsibilities, and if any corrective actions need to be taken for non-compliance.

An Environmental Management System audit can be conducted by internal or external auditors who analyze an organization’s operational procedures, documents, records and measurements against ISO 14001:2015 requirements.

The auditor will then report their findings and make recommendations on areas of improvement that need to be addressed. Achieving ISO 14001:2015 certification demonstrates that a company takes environmental responsibility seriously and is committed to reducing their environmental impact.

It also serves as a tool for continual improvement of environmental management system processes. A successful EMS audit is essential for an organization to remain compliant with ISO 14001:2015 standards and maintain their certification status.

Organizations looking to get certified under ISO 14001:2015 need to arrange for an EMS audit, in order to assess their current environmental management system and identify any areas that require attention as well as address significant environmental aspects. The auditor will also provide advice on ways to improve the organization’s EMS and suggest best practices.

A successful audit is essential for obtaining certification and achieving a high level of compliance with ISO 14001:2015 standards. To ensure a smooth audit process, organizations should have all necessary procedures, documents, records and measurements in place prior to the commencement of the audit.

Additionally, they should take the time to train their personnel on environmental policies and requirements so that they can answer any questions from the auditor.

 

What to expect during ISO 14001 audit?

The key stages of an EMS audit include:

– Preparation – development of the audit plan, followed by the assessment team’s familiarization with the requirements of ISO 14001:2015.

– On-site visits – review and analysis of documents, operating criteria, records and data, as well as interviews with relevant personnel.

– Reporting – summarizing of findings in a non-conformance report that identifies areas for improvement or corrective action.

– Follow up – implementing environmental management systems and the implementation of any identified corrective actions and verification that all issues have been addressed properly.

 

By completing these steps, organizations can ensure that their EMS meets the requirements of ISO 14001:2015 and is effectively implemented. Additionally, they can identify areas where processes or procedures could be improved to ensure continued compliance with environmental regulations.

Finally, an EMS audit can provide valuable insight into the environmental performance of an organization, helping them make informed decisions about how to reduce their impacts on the environment and save costs in the long term.

The environmental management system requirements are set in place to help each organization established environmental objectives and internal audits to aid in proper business processes incase of an unplanned external audit.

In addition to identifying issues and providing recommendations for improvement, a successful ISO 14001 audit should include education and training for relevant personnel in implementing the necessary corrective actions.

This will help to ensure that any changes or improvements identified as part of the audit process are properly understood and put into practice effectively.

Furthermore, regular audits help to ensure that any non-conformances are addressed in a timely manner and that the organization remains compliant with all applicable regulations. By undergoing periodic EMS audits, organizations can demonstrate their commitment to environmental responsibility and sustainability.

 

What are the basic requirements of ISO 14001?

  1. Scope of the Environmental Management System

    The organization’s activities, products and services should be clearly stated in the scope of the EMS.

    This should include a description of the organization’s operations, processes, sites, departments, divisions, etc., to identify any associated environmental aspects or any adverse environmental impacts. Any legal or other requirements that must be addressed should also be specified.

  2. Environmental Policy

    The Environmental Policy outlines the organization’s commitment to protecting and enhancing the environment, as well as meeting all legal requirements.

  3. Evaluation of Environmental Risks and Opportunities

    Risks and opportunities should be identified, evaluated, monitored and managed in order to minimize the environmental impact of the organization or to identify any significant environmental aspects. This will involve collecting data relating to environmental performance indicators such as air quality, water usage, waste production and energy consumption.

  4. Evaluation of Environmental Aspects

    Businesses have a responsibility to put in place measures to reduce the environmental impacts of their activities. This involves assessing what impacts are created and putting in place sustainable practices that minimize or eliminate them.

    Examples of such practices include reducing energy consumption, waste minimization, reusing materials and resources, and exploring renewable energy sources. Additionally, businesses must stay abreast of environmental regulations and laws, as failure to comply with these can lead to substantial financial penalties.

  5. Environmental Objectives and plans for achieving them

    The environmental objectives of your organization should be realistic, achievable and measurable. They should also cover both short-term and long-term goals for the business.

    To ensure that these objectives are achieved, it is essential to have a structured plan in place with clear steps toward achieving each one as well as keep maintained documented environmental objectives for all relevant interested parties.

  6. Operational Control Procedures

    Organizations must take responsibility for setting their own operational controls to ensure that they meet the requirements of ISO 14001.

    The standard provides guidance on how organizations should go about this, including defining and documenting relevant internal procedures; assessing environmental objectives; conducting risk assessments; and identifying any training needs.

    When it comes to implementing these operational controls, organizations need to ensure that they are appropriate for the sector they operate in and take into account any relevant legal or compliance requirements.

    Furthermore, organization should review these controls regularly to ensure that they remain effective and address any changes in legislation or industry practices.

  7. Procedure for Emergency Preparedness and Response

    With an emergency plan, your organization will be able to respond appropriately and effectively in the event of an environmental emergency. A well-developed plan should include clear roles and responsibilities for staff, methods for communicating with stakeholders, and a system for evaluating the effectiveness of response measures.

  8. List of Interested Parties, Legal and Other Requirements

    In order to ensure a successful management system, it is essential that the needs and expectations of all interested parties are taken into account. Understanding these interests provides an insight into how the organization’s operations can contribute positively to the wider environment.

  9. Competence records

    Recording the training and competence levels of every member of your organization is an important part of introducing and managing an EMS. A successful EMS requires all staff to have a good understanding of their environmental responsibilities.

  10. Evidence of Communication

    Internal and External communications are also a key part of your management system. You can use external communications to inform people in the community or industry about your environmental objectives, progress reports on performance metrics, initiatives you have introduced and successes achieved.

    This will demonstrate to stakeholders that your organization is committed to environmental improvement and accountable for its actions.

  11. Monitoring Performance Information

    In order to demonstrate continual improvement, your organization must measure its performance and effectiveness in relation to the objectives of ISO 14001. It is important to have a record of these evaluations so that you can track the progress made toward achieving those objectives.

  12. Compliance obligations record

    It is essential to stay up-to-date with all legal environmental requirements that your organization is subject to. This can be achieved by carrying out a competent evaluation of applicable laws and regulations and conducting regular reviews to ensure the record is accurate and current. Additionally, it should also be documented any obligations your organization has to other parties.

  13. Internal Audit Program and Results

    A regular internal audit of your EMS is essential for its ongoing effectiveness and the overall environmental performance of your organisation. An audit can help to identify any issues or opportunities for improvement that have been overlooked, as well as demonstrate compliance with processes set up as part of implementing an EMS.

  14. Management Review Results

    The results of a management review should be used to identify areas for improvement, as well as any corrective and preventive actions necessary. Furthermore, senior management should also provide feedback on the effectiveness of corrective and preventive action taken in response to the review results.

  15. Nonconformities and Corrective Action

    It is important that root cause analysis is conducted to identify the source of the nonconformity. This should include a review of any relevant documentation, as well as an examination of processes and/or procedures which may have contributed to the issue. Once a root cause has been identified, corrective action can be taken to prevent recurrence and ensure compliance.

    The corrective action should be documented clearly in your records, including the specific steps taken to ensure the environmental management system conforms to the new policy.

    This should include details of any training or process modifications that have been implemented, as well as any changes to procedures and/or equipment used. You should also identify the individuals responsible for each stage of the process.

     

What are the 3 C’s of ISO 14001 EMS auditing?

  1. Conformance
  2. Consistency
  3. Continual Improvement

 

What are the mandatory records for ISO 14001?

The mandatory records of ISO 14001 include: Records of competence, awareness, and training.

These records are essential to your environmental management system, as they provide evidence that those involved in the system are adequately trained and aware of their responsibilities.

They demonstrate to regulators and other stakeholders that you have taken steps to ensure that everyone is well informed on how to reduce your environmental impact. Records may include details of courses attended, training materials such as manuals or handouts, and any assessments made about an individual’s knowledge or ability.

Additionally, these records should be regularly updated so that you can track changes in personnel and keep up with advances in technology or processes.

By maintaining a clear record of who has been trained, when they were trained, and what specifically was addressed during the training session(s), you will be able to ensure that all parties understand their roles and remain up-to-date on the latest regulations and best practices.

Additionally, these records provide a basis for continuing improvement in your environmental management system by allowing you to identify gaps or areas where more training may be needed.

 

How do I audit a ISO 14001 checklist?

In order to achieve ISO 14001 certification, organizations must first develop an environmental policy that contains a commitment to continual improvement and compliance with applicable laws.

The organization must also create objectives and targets for their EMS. These should be aimed at reducing the company’s negative impact on the environment and can include such areas as energy efficiency, waste management, water conservation, emissions control, and pollution prevention.

The next step is to assess any existing environmental impacts of the organization’s operations. This assessment should identify risks or opportunities associated with environmental issues in order to develop mitigation strategies or take advantage of potential benefits.

Once these steps are completed, the organization needs to develop procedures related to all aspects of their environmental activities. These procedures ensure that employees are aware of their responsibilities and know how to handle environmental issues. The organization must also put in place a system for monitoring, measuring, and evaluating the performance of its EMS.

Finally, organizations must provide training to employees on the content covered by their environmental policy and procedures. They should also strive to continually improve their EMS by setting new goals or expanding upon existing objectives.

Doing so will help them maintain ISO 14001 certification while also reducing their negative impacts on the environment.

In summary, ISO 14001 provides organizations with an internationally recognized framework for designing, implementing, and improving an effective environmental management system that can be certified for.

 

Need Help?

iSi’s safety audit team can help you determine where you stand on compliance with OSHA regulations and provide a prioritized list of findings.  Contact us today to learn more about our audits!

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DYK: EHS Consultants

DYK: EHS Consultants

Aug 9, 2022

What does EHS stand for?

EHS stands for Environment, Health and Safety. Companies in a variety of industries have adopted EHS programs that not only ensure employees are safe at work, but also ensure that the quality of the environment and the health of the local community are protected from any hazards or consequences of the company’s operations, such as an accidental spill of dangerous substances.

By implementing these programs, businesses demonstrate their commitment to protecting both their employees and the communities in which they operate. Environmental, health and safety should be the main focus of very company and industry.

What are EHS process and procedures?

The right environmental, health, and safety (EHS) process is key to keeping your workplace safe. Here are a few steps that should be included in your EHS consulting services and EHS processes:

1. Establish Clear Policies and Procedures

Clear policies and procedures help everyone understand what is expected of them when it comes to safety. Make sure your policies are easy to understand and follow so that everyone can stay safe.

2. Educate Your Employees

It’s important to educate your employees on the dangers of their work and how to stay safe. Provide training on a regular basis so that everyone is up-to-date on the latest safety information.

This shows you value and support your employees and want to make sure they have the best resources and systems in place.

3. Get Everyone Involved

Safety is a team effort. Encourage everyone to be involved in the safety process, from management to front-line workers. By working together, you can create a safer workplace.

4. Inspect Your Workplace Regularly

Regular inspections help identify potential hazards before they cause an accident. Make sure to inspect both common areas and individual workstations. Also, it is important to get EHS management consulting regularly as law and regulations can change annually.

5. Invest in Safety Equipment

Investing in the right safety equipment can help protect your employees from accidents and injuries. Make sure you have the right equipment for the job and that it is properly maintained.

What does an EHS consultant do?

EHS consultants hone in on environmental and safety issues and identify potential risks for their clients as early as possible so that they can be reduced or eliminated as well as offer compliance services and professional services.

However, when adverse events do occur at work, the consultant will conduct an investigation and research into what went wrong.

The role of an EHS consultant is to protect workers from harm and help businesses avoid environmental damage. They do this by assessing risks, investigating accidents and advising clients on health and safety best practices.

An EHS consultant typically has a background in occupational health, safety or environmental management and EHS compliance.

They use their knowledge to advise clients on a wide range of issues including air quality, noise levels, waste disposal, and chemical safety.

Conclusion

In conclusion, businesses that focus on the implementation of employee health and safety programs demonstrate their commitment to protecting both their employee’s health and the communities in which they operate.

By taking these precautions, businesses can reduce the risk of injuries, improve the overall safety of their workplace and create positive outcomes.

How Can We Help? Ask a Question or Request Info or Pricing

Do you need an idea of where you stand with EPA or OSHA regulations?  Do you need full-time or temporary personnel to manage the day-to-day compliance tasks?  Would your employees benefit from onsite environmental training?  Our team of environmental consultants, safety consultants and industrial hygienists would love to help. Call (316) 264-7050 today!

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Sustainability Software

Sustainability Software

Jul 16, 2022

Sustainability software is a powerful tool for businesses and organizations that are looking to become more sustainable and reduce their carbon footprint. This type of software collects data on energy usage, waste disposal, water consumption, and other environmental factors in order to measure the sustainability performance of an organization or business.

It can provide detailed reports showing which areas need improvement as well as suggest ways to reduce emissions and optimize resource use. By collecting this data, companies can set goals and reach them with greater accuracy and efficiency than ever before.

With sustainability programs, organizations have the power to make a real difference in the world around them while also saving money in the long run by reducing their energy costs. In short, it’s a win-win proposition for everyone involved.

Sustainability software is an important tool in the fight against climate change. By taking a more holistic view of sustainability, companies can make decisions that will benefit everyone – from individuals to corporations, and even entire nations.

The data provided by these solutions helps organizations and businesses understand where they stand with regards to their ESG goals and objectives, while also providing them with the tools they need to achieve their desired results. With the right software in place, organizations are well on their way towards making sustainable progress for years to come.

What is Sustainability Software?

Sustainability software is a type of technology that helps organizations reduce their environmental footprint. It provides tools and resources for companies to track, monitor, and improve the sustainability performance of their operations. By utilizing data-driven insights, businesses can make informed decisions about how to reduce waste, increase energy efficiency, and ultimately create a sustainable future.

Sustainability software also helps organizations stay in compliance with regulatory bodies by providing visibility into their current eco-friendly initiatives. With this kind of software available, it’s never been easier for businesses to make meaningful changes toward creating a more sustainable world.

10 sustainability management software providers to consider:

  1. IBM

  2. Metrio

  3. Microsoft

  4. FigBytes

  5. Ecometrica

  6. Benchmark Digital Partners

  7. Diligent ESG

  8. OneTrust

  9. Persefoni

  10. SAP

Sustainability and ESG Data & Reporting

Sustainability data and ESG (Environmental, Social, and Governance) data are an increasingly important part of corporate responsibility. Companies are now under pressure to demonstrate their commitment to upholding the highest standards of ethical conduct in all of their operations. As a result, sustainability reporting and ESG reporting have become key components of effective corporate governance.

Companies must be able to clearly articulate the steps they are taking to reduce their environmental impact, address issues related to employee welfare, or improve governance structures. By doing so, companies can help ensure that stakeholders have faith in their commitment to responsible business practices and set themselves up for long-term success, especially with ESG and sustainability reporting.

Not only does this type of reporting help ensure that a company is adhering to best practices but it also helps them stand out in the market and attract more customers. In today’s globalized economy, businesses must prioritize sustainability reporting and ESG reporting if they want to thrive in an ever-changing landscape. These should act as your company’s reporting solutions which will generate reports that drive data reliability and sustainability goals.

Key features in sustainability management software

Sustainability management software is designed to help businesses and organizations track, measure, and manage their sustainability efforts. The key features in this type of software include data collection capabilities, reporting metrics tools, visualization dashboards, risk analysis tools, and integration with other systems.

Data collection allows organizations to collate information from numerous sources including internal business operations, external environmental sources, and more. Reporting metrics provide insights into the organization’s sustainability performance and how it can be improved.

Visualization dashboards allow users to easily comprehend complex data in an interactive format. Risk analysis tools offer more sophisticated insights into potential risks associated with a business or organization.

Lastly, integration with other systems allows for seamless integration of various data sources and a unified view of sustainability performance. With all these features, organizations can better understand the impacts of their sustainability initiatives and how to improve them.

Benefits From Professional Sustainability Management Solutions

Leading sustainability software providers can help businesses achieve their environmental and social objectives, as well as reduce costs. These solutions provide businesses with tools to improve their efficiency and reduce energy consumption, thus reducing their carbon emissions and overall carbon footprint.

Additionally, by understanding the impacts of their operations and taking appropriate action, businesses are able to increase the value of their products or services more sustainably. Furthermore, sustainability management solutions can help businesses with their public relations, as they demonstrate a commitment to social responsibility.

With Metrio sustainability reporting software, you can easily collect, analyze, disclose, report and communicate your ESG data. Our software enables organizations to compare and save data in a centralized platform, enabling better decision-making and improved corporate sustainability performance.

Finally, by understanding the current and potential impacts of their operations, businesses can create positive relationships with stakeholders by implementing responsible strategies for long-term sustainability which ultimately empowers organizations.

Sustainability Progress – The Need is High, But Progress is Slow

Sustainability Progress is an integral part of achieving a more sustainable global future. It involves making changes to our lifestyles, businesses, and communities that promote environmental responsibility and long-term economic growth.

Through setting and monitoring progress goals with specific targets, companies can track their own performance while demonstrating commitment to corporate sustainability objectives. Stakeholders are able to assess and evaluate a company’s commitments to sustainability, enabling better decision-making and improved corporate transparency.

Net-Zero Emissions Targets are a Top Priority

Net-Zero Emissions is an important concept in the global effort to reduce greenhouse gas emissions and prevent further climate change. This goal seeks to achieve a balance between releasing carbon into the atmosphere and removing it from the atmosphere by using strategies such as renewable energy production, carbon accounting, energy efficiency measures, and carbon capture and storage technologies. This can help campnys measure and manage their portfolio exposure to climate risks and financed emissions as they navigate the risks and opportunities in the net-zero transition.

The ultimate aim is for society to reach a point where the level of greenhouse gas emissions released is equal to the amount that is taken out, thus creating a cycle of zero net emissions. Emissions management software can help achieve this goal.

Tackle your Scope 3 Challenge

As with any challenge, the first step to success is understanding the problem. When it comes to tackling Scope 3 emissions, this means gaining an in-depth knowledge of your business’s sources of emissions and the different strategies you can use for reducing them. Once you have a clear picture of what needs to be done, you can start mapping out your Scope 3 emissions reduction plan, taking into account all of the relevant stakeholders and resources.

Ultimately, as part of a good sustainability strategy, you’ll need to develop a comprehensive action plan for reducing emissions, based on the best practices for energy efficiency and low-carbon operations. Setting targets and timelines will help you stay focused and motivated towards achieving your goals.

Finally, consider how you can collaborate with other companies in order to share expertise and resources, which will make it easier to reduce emissions across your entire supply chain. With careful planning and commitment, you can make strides towards meeting your Scope 3 emission reduction objectives.

Are you ready to start your Corporate Sustainability journey?

Our team of experts can help you with whatever compliance issues you may be facing. Whether it is understanding the complexities of a given regulation or recognizing where your company needs to improve, we have the necessary skills and experience to provide assistance. We will take the time to understand your unique needs and develop tailored solutions that address those needs. For facilites looking for help navigating the often perplexing regulatory landscape, contact us today!

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iSi’s Top 8 Gaps Found in Environmental Audits

iSi’s Top 8 Gaps Found in Environmental Audits

Jul 16, 2022

​Environmental regulations are enforced by federal, state and local governments. How do you make sure you have your bases covered? An environmental audit can determine your current status and what your vulnerabilities are.

iSi’s environmental audits cover air, wastewater, stormwater, waste, spill prevention, tanks, DOT and emergency planning (EPCRA) requirements. They are a mock regulatory audit, looking at all aspects of your program through data gathering, walkthroughs and records reviews.

The following are our top 8 areas of compliance we see issues with when we do our audits.

Inaccurate Permits, Registrations & Notifications

What your facility does will determine which of these you need.  For example, have you notified the proper agencies regarding your spraying, blasting, emitting, generating, collecting, storing, disposing, dumping and discharging operations?

When do your permits expire?  Do your permits reflect the operations you’re conducting now?

Notifications may need to be made to EPA, your state authority, and in some cases, municipal authorities.  Many times there will need to be notifications made BEFORE you do these operations in addition to during and after.

Have you made determinations on what category of air emissions source you are or what classification of hazardous waste generator you are?  Who do your storage tanks need to be registered with?

Inaccurate/Incomplete Facility Plans

Specific written plans are required depending on what you do or have onsite. Which apply to you? Are they updated on the frequency required?  Some examples include:

  • Operations and Maintenance (O&M) Plans
  • Work Practice Implementation Plans (WPIP)
  • Storm Water Pollutions Prevention Plans (SWP3)
  • Spill Prevention, Control and Countermeasure (SPCC) Plans
  • Facility Response Plans (FRP)
  • Emergency Response Action Plans (ERAP)
  • DOT Security Plans
  • Hazardous Waste Contingency Plans
Missing/Incomplete Facility Inspections

Are you conducting the inspections which apply to you, on the frequency required?  What documentation is required?  Some typical issues we see missing inspections include:

  • Air
  • SWP3
  • SPCC
  • FRP
  • DOT
  • Hazardous Waste
Missing/Incomplete Facility Tracking

Are you tracking your air emissions correctly? What about waste generation? Tier II or Form R chemicals?  In many cases what you purchase and how much you use need to be tracked.  What do your permits require?  Are you past the usage allowed?  Have you changed a process which was not accounted for in the permit?

These are the areas many companies do not track their usage:

  • Air Emissions
    • Volatile Organic Compounds
    • Hazardous Air Pollutants
    • Particulate Matter
  • Waste Generation
  • Tier II
  • Form R
Inaccurate/Incomplete Reporting

We see a lot of issues with inaccurate and incomplete reporting.  This affects all areas of environmental issues. Reports can be required to monthly, quarterly, semi-annually, and annually?  What does your state/city/county require vs. what’s required federally?

When you have a spill, who are you reporting that to?  There are federal and state regulations which require you to make phone calls to certain authorities based upon the quantity and location.  Besides 9-1-1 or your spill contractor, you may need to report a spill to local emergency planning, the National Response Center, your state authorities.  Do you have a plan for this?  Have you done this and is it documented?

Inaccurate/Undocumented Training

Have you conducted the training you are required to?  Are the right people trained?  In addition to environmental training, please keep in mind that some regulatory agencies cross over in their requirements.  Don’t assume that because you’ve had hazardous waste training, that will suffice for shipping hazardous materials, or if you’ve had OSHA HAZWOPER training that will work for hazardous waste.  There are differences between EPA, OSHA and Department of Transportation (DOT) regulations and the training required for each.

Annual training is required for hazardous waste and per many environmental plans.  Do you have a mechanism to track this?  Are you doing this and has your training been documented?

Do you have job descriptions on file for your people?

Incomplete/Inaccurate Records

Are you keeping required records? Where are they kept and for how long?  Documentation is critical and will save you from many hassles in an inspection.  Are you keeping records for onsite inspections, training, and notifications?  Are they easily accessible?

Poor Day-to-Day Facility Management

Is there a disconnect in the proper way to do something vs. how it’s actually being done?  Spot checks and walkthroughs are just as important for environmental issues as they are for safety.  Many times we see worksites where the same issues keep cropping up on a regular basis.  Are issues you’ve been cited for in the past still popping up at your facility?

For example, are your hazardous materials going into the proper containers?  Are the containers closed and sealed?  Are they properly labeled?  Have your hazardous waste containers been sitting onsite for past the allotted time frame?  What are you doing with your spent fluorescent bulbs?

Do you have proper containment around your tanks?  Are containments cracked or able to leak?

Where is your stormwater being directed?  Do you have vehicles or equipment which leak oils that could come into contact with rainwater where the oils could be transported offsite?

Some of the most common areas we see issues include:

  • Air Emissions
  • Stormwater
  • SPCC
  • Waste
  • DOT
Where Do You Go From Here?

iSi can help you get a baseline on your environmental compliance responsibilities and help you prioritize the ones which are most critical to be taken care of.  Request a quote for an environmental audit today!  Need more information about these issues?  Contact us at (888) 264-7050 or email us!

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iSi Environmental – Hazardous Waste Disposal

iSi Environmental – Hazardous Waste Disposal

Jul 1, 2022

Hazardous waste management is essential for your operations. Our responsive hazardous waste management services provide safe, compliant, and sustainable solutions for the collection, disposal, treatment, recycling, and transportation of hazardous waste materials. With three decades of experience in the industry and a national network of facilities and transportation infrastructure, our team is equipped to meet all your hazardous waste management needs.

Choose iSi Environmental for Hassle-Free Hazardous Waste Disposal!

You and your company want to be environmentally responsible, but you struggle to find reliable companies for your hazardous waste disposal. With global supply chain and transportation disruptions, all businesses are looking for responsive and reliable services, at a fair price. Today, more than ever, getting a competitive price from a waste disposal company requires sacrificing predictable transportation. It doesn’t have to be this way, and, frankly, your facility management expects more from their waste disposal company. Businesses cannot afford to have containers sitting on the loading dock, disrupting production, and causing service delays to your end customers.

iSi Environmental is a leading provider of hazardous waste industry services. Our team has over three decades of experience working with facility hazardous waste, and we are committed to providing safe, compliant, and sustainable solutions for your needs. Whether you need to dispose of electronic waste or industrial products, we have the hazardous waste experts and resources to help you achieve your goals. With our professional services, you can rest assured that your hazardous waste transportation will be handled in a responsible and compliant manner. Contact us today to learn more about our services and how we can help you!

The iSi Environmental Advantage:

– Trusted leader in hazardous waste services with over 30 years of experience

– Offers many benefits, including peace of mind knowing that your waste disposal will be managed responsibly and in compliance with all regulatory requirements

– Team of hazardous waste experts committed to finding safe, compliant, and sustainable options for the widest range of waste streams

– Nationwide network of facilities and transportation infrastructure

– Flexibility to meet all your hazardous and non hazardous waste disposal needs

– Focus on process safety, compliance, and sustainability

– Extensive experience and expertise in hazardous waste management services

– Dedicated to helping our customers achieve their hazardous waste disposal goals

– Commitment to excellence ensures that all our services meet the highest standards

– Effective and reliable hazardous waste removal solutions that are safe, compliant, and sustainable.

What is hazardous waste and why do I need to manage it?

Hazardous waste is any waste that poses a potential threat to human health or nature. It can be any type of waste, from industrial and commercial waste to household products. Managing hazardous waste presents unique challenges and is essential for protecting people and our earth from the potential hazards posed by these materials.

What are the different types of hazardous waste?

There are many different types of hazardous waste, including industrial waste, medical waste, electronic waste, universal waste products, radioactive waste, waste sludge, non hazardous waste, and household hazardous waste. Each type of waste has its own unique set of hazards that need to be managed appropriately.

How can I safely dispose of my hazardous waste?

Disposing of hazardous waste can be difficult and confusing. There are many different methods for disposing of hazardous waste, and each disposal method has its own set of risks and benefits. Hazardous waste disposal can be accomplished through a variety of methods, including treatment, landfills, recycling, and incineration. The best removal option for hazardous waste will depend on the type of waste and the specific regulations in your area. Working with professional hazardous waste disposal services can help ensure the removal of waste is handled safely and legally.

What are the benefits of using a professional hazardous waste management service?

Professional hazardous waste disposal services offer a number of benefits, including expert knowledge and guidance, cost-effective solutions, reliable transportation and storage options, and compliance with all local regulations. Whether you need removal of liquid or solid hazardous waste, non hazardous waste, or household products, working with a reputable hazardous waste experts can help ensure that your waste is handled safely and responsibly.

The Hazards of Hazardous Waste

Hazardous wastes pose many risks to human health and the planet, including contamination of soil and water, damage to ecosystems, and exposure to toxic chemicals that can cause serious health problems. Disposing of hazardous waste safely is essential for protecting people and the environment from these hazards.

Why You Can’t Afford to Ignore Hazardous Waste Management

Hazardous waste administration is a critical part of any business or organization, yet many people choose to ignore this important issue. Whether you are dealing with industrial waste, non hazardous waste, or household products, failing to manage your waste disposal responsibly can lead to serious consequences, including hefty fines, damage to your reputation, and even jail time. Ignoring hazardous waste is simply not an option if you want to protect your business or organization.

How iSi Environmental Can Help You with Your Hazardous Waste Disposal Needs

iSi Environmental is a leading provider of hazardous waste disposal services. We offer a wide range of management solutions for the collection, transportation, and disposal of hazardous waste materials. With more than three decades of experience in the industry, our team is equipped to handle any hazardous waste disposal challenge. iSi’s hazardous waste disposal experts can create a safe, cost-effective, and legal treatment approach for the disposal of your hazardous materials and byproducts regardless on their size or content. We offer responsive customer service, competitive pricing, and a commitment to compliance with all local, state, and federal regulatory guidelines. Contact us today to learn more about our hazardous waste disposal services process and how we can help you keep your organization safe and compliant. Responsive and attentive service is only one call away.

Disposal Services:

  • Radioactive Waste
  • Industrial Waste
  • Lab Packs
  • Sludge
  • Chemical Waste
  • Medical Waste
  • Toxic Waste
  • Paint Waste
  • Non Hazardous Waste Disposal
  • Hazardous Waste Removal
  • Containers and Supplies
  • Facility Management

Disposal Facility Options:

  • Recycling
  • Landfill
  • Underground Storage
  • Incineration
  • Fuel Blending Facilities

 

Questions to ask your hazardous waste disposal companies:

 

Will the onboarding and implementation process be time consuming?

iSi Environmental’s waste disposal services offers a seamless onboarding experience. Responsive client service has allowed our firm to experience continuous growth over the last three decades.

Do your disposal facilities handle radioactive waste?

With a wide variety of disposal solutions, iSi will work to find appropriate disposal options for your radioactive waste.

Do you offer on-site logistics management services?

Our Facility Support Services can help you to streamline facility operations and allow your team to better focus on supplying products to the end customers. With experience in transportation, logistics, warehousing, and onsite waste and recycling activities, we have unique experience to benefit your operations.

Do you offer a wide array of disposal facilities and treatment technologies for my waste? (landfill, incineration, recycling, or reuse facility disposal options)

We offer a wide range of disposal facilities and treatment options, including landfill, incineration, recycling, or reuse facility disposal options.

Are you familiar with my industry specific, local, state, and federal regulations?

iSi has performed waste consulting in 30+ states across the United States. Having worked in production facilities prior to consulting, our staff has wide ranging industry knowledge. As a backup, we use a software that highlights industry specific regulatory requirements by state and municipality.

Can you provide examples of similar disposal projects?

On request, we can provide examples of similar disposal or recycling projects.

What types of containers can you provide to us?

We offer a wide variety of containers, including drums, totes, bags, and boxes. We also have a wide range of capacities available, from small to large. Please feel free to contact us at 888-264-7050 and we would be more than happy to help you select the right container for your needs.

Can you provide a origin/destination workflow for my paint waste, toxic waste, sludge, chemical waste, or medical waste?

Yes, we can provide an origin/destination workflow for your paint waste, toxic waste, sludge, chemical waste, or medical waste. Please feel free to contact us at 888-264-7050 and we can discuss your specific workflow needs.

Do you offer hazardous waste removal or remediation services?

Outside of disposal services, we have a separate division within iSi that can assist with the removal of hazardous waste and perform remediation service at your facility

How quickly can you deliver lab packs to my facility?

Depending on facility location, iSi can usually deliver lab packs as soon as 24 hours. Please feel free to contact us and we would be more than happy to confirm availability and delivery time for your specific needs.

Do you offer containment materials and PPE for purchase?

Our convenient software platform provides all the containment materials and PPE a facility could need. We participate in a consortium of buyers that allows our clients to receive a competitive price on all available items.

Would you be able to share business references from companies similar to mine?

We would be happy to share business references from companies similar to yours. Reach out to us at 888-264-7050 and we will provide you with any information you need.

Do you offer bulk on-site liquid storage containers?

Yes, we offer a variety of bulk on-site liquid storage containers. Our service partners carry a variety of container types and sizes. We would be happy to discuss options with you.

Can you assist in a zero waste to landfill program?

iSi is available to assist your management team in pursuit of sustainability and your ‘zero waste to landfill’ strategy. Our years of experience inside industrial settings can aide in the removal of defaulting to landfill for your hazardous waste disposal needs and shift the focus to recycling and reuse.

Where can I dispose of paint in Wichita KS?

Chemical waste is not acceptable. Instead bring it to the local household waste disposal facility, located at 801 Stillwell, Wichita, KS 67213. The cost is zero.

Are there Kansas hazardous waste disposal options?

Services are available statewide and across the region. Specific cities served in this region include:

  • Wichita, Kansas
  • El Dorado, Kansas
  • Kansas City Metro Area
  • Omaha, Nebraska
  • Oklahoma City, Oklahoma
  • Tulsa, Oklahoma

What is considered hazmat waste?

Hazardous waste are materials that may be harmful to human health and environmental conditions. Hazardous waste can be solid, liquid. They are a collection of discarded materials, such as cleaning fluids or chemicals, as well as byproducts from manufacturing processes.

What is a Subtitle C landfill?

Subtitle C landfills include Hazardous Waste Landfills. These are specialty sites that accepts hazardous waste for disposal. This waste disposal system has no use as a waste dump.

How do I dispose of old CNC coolant?

If a fluid waste is not considered nonhazardous, the material may be disposed at the treatment plant or if the sewer is allowed into the water supply, discharged into the municipal sewer system for non hazardous waste disposal.

How do you get rid of chemical waste?

Chemical waste is regulated under the Resources Conservation and Recovery Act of the United States (RCRA). The materials are not acceptable for disposal at sewage treatment stations or in the normal garbage collection. Almost all chemical waste is disposed of as EHS hazardous waste.

How do companies get rid of chemicals?

Since industrial biproducts may cause harm to humans and the planet, environmental protection agencies are imposing restrictions on industrial chemicals. The most common disposal procedures are burning waste incinerated land or infiltration of underground water.

How do you get rid of a biohazard?

All biohazard liquids are preferably autoclavable before disposal.

How do companies get rid of toxic waste?

The Environmental Protection Agency has restricted the disposal of industrial chemicals. Incineration is a common treatment process and land and underground injection holes are also available to remove waste.

What certifications do your drivers have?

Our drivers are certified in hazmat transportation. Please feel free to contact us at 888-264-7050 and we would be more than happy to help you with your specific needs.

Need Assistance?

Let iSi’s EHS team help you improve your company’s hazardous waste compliance.  How can we help?  Contact us!

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Incorporate Sustainability Action Plans Into Your Preconstruction Submittals

Incorporate Sustainability Action Plans Into Your Preconstruction Submittals

Jun 15, 2022

How to Incorporate a Sustainability Action Plans Into Your Preconstruction Submittals

A Sustainability Action Plans (SAP) is a critical part of any successful sustainable construction project and sustainable business. By creating and implementing a SAP, you can ensure that your construction project will be environmentally responsible and meet or exceed all applicable environmental sustainability standards. These action plans are designed to help both the environment and your build in the present and future. A few issues that it can aid is renewable energy, air pollution, climate change, as well as many other environmental issues. In this article, we will discuss how to incorporate Sustainability Action Plans into your preconstruction submittals.

If you’re a construction project manager, then you know that preconstruction submittals are a critical part of the process. If you are working on a federally funded project, then you have probably been asked to include Sustainability Action Plans and Sustainability eNotebooks.

Incorporating a sustainable action plan into your preconstruction submittals can be a challenge, but it’s worth the effort. Here are six tips to help you get started:

  1. Define what sustainable features are required to include in your project (ie. Sustainability performance, energy usage, etc.)
  2. Do your research on which sustainable materials are available and how they can be used (ie. recycling bins)
  3. Work with your architect and engineers to see how these materials can be incorporated into the design
  4. Make sure that the contractors you hire are aware of your sustainability goals and are willing to work with you to achieve them
  5. Be prepared to make some sacrifices – not all sustainable materials are going to meet project specifications, be prepared to clarify why they won’t work
  6. Remember that a sustainable project is an investment in the future, both for yourself and for the planet

By following these tips, you’ll be on your way to creating a more sustainable construction project!

Define what sustainable features are required to include in your project

Guiding principles and requirements for a viable project are essential and include elements of energy efficiency, bioswales, green roofs, renewable sources, and an effective waste management plan.

These guiding principles should be woven in with the initial design and planning stages of any project to ensure that it is both efficient and environmentally conscious. Any development must maintain the guiding principles set out as required by law. In addition, developing a waste management plan that can be implemented during construction and throughout the life-cycle could be beneficial from a cost perspective as well as from an environmental one.

Sustainable features should always factor into any project if you are looking to keep your operations on track, make your customers happy, and show you are a green business.

Do your research on which sustainable materials are available and how they can be used

If you’re looking to create a sustainability plan, one of the keys to success is researching and finding sustainable materials that can be used to reduce overall waste.

With a wealth of options available today, it pays off to put in the effort to find the viable and suitable sustainability initiatives that can be incorporated into your projects. Sustainable products come at various prices and have different strengths and energy efficiency profiles, so it’s important to evaluate them thoroughly for each project.

Doing your research upfront will ensure you are making informed decisions about incorporating sustainability into your operations. Time spent now creating a sustainability plan will pay off big time in the future!

Work with your architect and engineers to see how these materials can be incorporated into the design

Working with your architect and engineers is the key to successfully incorporating new materials into the design. It’s important to have a well-thought out plan for how best to use these materials so that you get the most out of them without wasting resources.

Take advantage of the insight, knowledge and experience available from your team of professionals – clearly communicate your vision and objectives, then take their advice on board to ensure a successful outcome. Time spent discussing with your architect and engineers upfront is much more profitable than trying to figure it out yourself later down the track.

Make sure that the contractors you hire are aware of your sustainability goals and are willing to work with you to achieve them

If you’re serious about sustainability, you need to make sure that the contractors you bring on have the same commitment. It’s not enough for them to just say they support your goals; they need to also be willing to put in the work and effort.

Do a thorough vetting process and make sure that any personnel working with you are willing to do their part in meeting environmental objectives. If not, it defeats the purpose of having those goals in the first place.

Don’t let anyone slip through the cracks — be vigilant and ensure contractors are up-to-speed on your sustainability plans or else keep looking until you find someone who is.

Be prepared to make some sacrifices – not all sustainable materials are going to meet project specifications, be prepared to clarify why they won’t work

Sustainable materials are integral to any project, but you’ve gotta be prepared to make some sacrifices along the way. While not all sustainable materials may meet your specifications, it’s paramount that you understand why and explain that reasoning.

Don’t expect every viable alternative to perfectly fit your criteria – compromise is the name of the game in order to ensure that our work is as future-proof as possible. Taking shortcuts here will likely come back to bite you down the road, so don’t be afraid to get into the nitty-gritty of why a particular material won’t work for your needs – it could end up being an invaluable lesson.

Remember that a sustainable project is an investment in the future, both for yourself and for the planet

When it comes to sustainability, no effort is too small. Investing in projects that are meant to minimize human damage and preserve the planet for generations to come is essential; if we don’t look out for our environment, nobody else will.

It’s a matter of personal responsibility – taking charge of our own impact on the world around us and recognizing that every action we take can have positive or negative ramifications. It may be expensive up front, but a sustainable project is an investment in both your future and the future of the planet, guaranteed to pay dividends in more ways than one.

For instance, the resources in your project specific Sustainability Action Plans can be converted directly in to a corporate level sustainability program, helping to reduce waste on future projects as well.

Sustainability is important for a number of reasons. It’s not just about being environmentally friendly or socially responsible – though that is certainly part of it. It’s also about creating a project that will be able to stand the test of time, both in terms of its physical durability and its relevance to the needs of future generations.

Developing a sustainable project can be challenging, but it’s definitely worth the effort. If you need help getting started, don’t hesitate to reach out. We’re happy to assist you in developing and implementation of a Sustainability Action Plan for your next Federal Project.

Need Assistance?

Let iSi’s EHS team help you improve your company’s EHS compliance outlook.  How can we help?  Contact us!

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