iSi’s Top 8 Gaps Found in Environmental Audits

​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!