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

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

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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EPA Makes Final Rule to Update RMP Requirements

EPA Makes Final Rule to Update RMP Requirements

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!

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2024 EPA and OSHA Compliance Deadlines

2024 EPA and OSHA Compliance Deadlines

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

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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The Importance of Water Audits: A Comprehensive Guide

The Importance of Water Audits: A Comprehensive Guide

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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What is a Phase II Environmental Site Assessment?

What is a Phase II Environmental Site Assessment?

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.

Need Help?

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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?

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.

Need Help?

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!

Need Help?

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

Need Help?

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

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.

Need Help?

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

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

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

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.

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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

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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Health and Safety Consultants

Health and Safety Consultants

Consultants provide essential services to businesses, organizations, and individuals. They help ensure workplace safety by providing advice on health and safety regulations and policies, developing risk assessments, inspecting equipment or premises for safety hazards, conducting staff training sessions and developing emergency response plans.

These are knowledgeable in areas such as occupational health and safety regulation compliance, industrial hygiene principles, ergonomics, hazardous material management, fire protection engineering, accident investigations, construction site hazard recognition and more. Their expertise helps mitigate the risk of injury or illness within a work environment.

Additionally they can assist organizations in meeting all legal requirements for health & safety legislation in their respective countries or regions. Ultimately their work helps protect workers from potential hazards that may arise from working conditions.

Furthermore, safety consultants and safety professionals can provide a valuable service to businesses looking to expand or introduce new processes or practices. They can provide advice on the best practices for their particular industry, as well as how to best implement them with minimal risk of disruption to the operations.

Ultimately, this helps make sure that employees are working in an environment where their safety is paramount. Engaging with a qualified Health and Safety Consultant is essential for ensuring that an organization meets its legal obligations in terms of health and safety regulations and requirements.

Additionally, it allows companies to minimize risks, create a safe work environment for their staff, and ultimately protect their reputation should an incident occur.

OSHA Compliance Solutions

OSHA Compliance Solutions is a comprehensive suite of tools and services designed to help businesses stay in compliance with all applicable Occupational Safety and Health Administration (OSHA) regulations. The service includes access to the most up-to-date federal and state information, as well as an online library of safety training materials, safety programs, safety manuals, instructional videos, and other resources for your safety manager to use.

With these tools, businesses can easily create compliant work environments that protect employees from safety risks and injury. Additionally, OSHA Compliance Solutions can recommend a safety consulting company in which offers consulting services and technical assistance to further support companies’ compliance efforts.

These services include onsite visits for inspections or consultations, as well as identify workplace hazards and provide recommendations for corrective action plans when necessary. Your company will also be presented safety data sheets from these experienced safety professionals. OSHA Compliance Solutions helps businesses ensure their workplaces are safe, efficient, and in compliance with federal and regulations.

OSHA Training Solutions

OSHA Training Solutions is an industry leader in occupational safety and health training. With expertise on a wide range of topics related to workplace safety, OSHA Training Solutions provides comprehensive training courses, both online and in-person, to help employers meet their safety and health compliance requirements.

Their courses are designed to cover topics such as ergonomics, fall protection, hazardous materials handling, risk assessment, health programs, machine guarding, fire safety and more. They also offer a vast selection of online resources that provide easy access to up-to-date information on the ever changing regulations governing workplace safety. OSHA Training Solutions is committed to providing outstanding customer service and quality training solutions to ensure that workers stay safe while on the job.

With their commitment to excellence and dedication to helping employers protect their workforce from injury or illness, OSHA Training Solutions has become an industry leader in occupational safety and health training.

OSHA Compliance Evaluations

OSHA Compliance Evaluations are conducted in order to assess the safety and health conditions of a workplace and ensure that it is compliant with federal standards. During such evaluations, an inspector will look for potential hazards review company policies and procedures, inspect work areas, and verify compliance with OSHA regulations.

These evaluations also serve as an opportunity for employers to address any existing or potential safety risks before they become larger issues. Ultimately, OSHA Compliance Evaluations make workplaces safer places by identifying and preventing potentially dangerous situations.

Additionally, these evaluations can help employers save costs associated with employee injury or illness due to unsafe working conditions. By conducting assessments regularly, companies can protect the health and well-being of their workers while also avoiding violations of regulatory standards.

OSHA Inspection Guidance

The Occupational Safety and Health Administration (OSHA) provides inspection guidance to ensure compliance with federal safety standards. During OSHA inspections, OSHA inspectors conduct workplace inspections to assess compliance with safety regulations and identify any potential hazards that could cause harm to workers.

Inspectors may also speak with employers and employees during the inspection process in order to gather more information on working conditions. The inspector will then issue a report which includes recommendations for improvements or corrections based on their findings, along with a citation of violations if any were found. Employers must take the necessary steps to address the concerns raised in the report in order to come into full compliance with all applicable regulations.

By providing timely guidance and enforcement, OSHA helps keep workplaces safe from injury and illness, protecting both employers and employees.

Written OSHA Program Preparation

Written OSHA Program Preparation is an important part of any workplace safety program. It involves the development and implementation of policies and procedures for keeping workers safe from potential hazards. This includes identifying and addressing potential safety issues, training employees on safe practices, documenting all safety measures, and regularly auditing the system to ensure amenability with federal regulations. Taking these proactive steps helps to protect workers and create a safer work environment.

By setting up an effective written OSHA program, employers can ensure that their workplace is compliant with all applicable laws and regulations, while also protecting the safety and wellbeing of their employees. Written programs provide a roadmap for achieving workplace safety goals as well as creating an environment where employees understand the risks associated with their work and feel empowered to take action for protecting themselves and their colleagues.

Safety Data Sheet Preparation

A Safety Data Sheet (SDS) is a key document required by all employers to ensure the safety of workers in hazardous working conditions. SDSs are prepared to provide information about the properties of a particular substance or mixture, including its health and safety hazards, protective measures for handling, storing, using and disposing of it safely.

SDSs also include details on how to respond in case of an emergency involving the product. Preparation of SDSs requires knowledge of hazardous substances as well as knowledge of composition, toxicology and occupational health. Since many hazardous materials can exist in a number of different forms, it is important to ensure that the SDS accurately reflects the particular product’s characteristics. Furthermore, information must be regularly updated in line with changes in legislation and any new or revised hazard assessment data.

Health and Safety Program (HSP) Development

Health and Safety Program (HSP) Development is a comprehensive process that involves identifying potential risks, developing strategies to reduce risks and implementing those strategies in the workplace. A successful HSP requires proper planning, training, assessment and reporting of safety issues. The goal of HSP development is to protect workers from injury or illness associated with their job duties.

Emergency Response Plans

Emergency response plans are important to have in place for any organization, as they help to outline the steps that should be taken in the event of an emergency. These plans should include information about how to respond and evacuate a building safely, who is responsible for different aspects of the plan, and how to contact emergency services. This response plans should also consider potential risks, such as natural disasters or hazardous materials spills, and outline procedures for responding effectively.

Having a well-developed emergency response plan helps ensure employees are safe during an emergency situation, while also preventing costly damages if an incident occurs. Additionally, proper training on these plans allows staff members to become familiar with their roles so they can act quickly in the face of danger.

On-Site Health and Safety Management

On-site health and safety management is an essential part of any successful business. Effective management of workplace safety can help reduce risks, minimize injury and illness, protect employees’ rights to a safe work environment, and ensure that businesses meet all applicable safety regulations.

An effective on-site health and safety management system should include procedures for identifying hazards in the workplace, setting standards for worker protection, providing training for workers on how to safely conduct their job duties, responding quickly to reported or observed unsafe conditions or practices, conducting periodic inspections of the facility for potential hazards, and maintaining records documenting compliance with OSHA regulations.

LOTO Procedure Development

LOTO (Lock Out/Tag Out) Procedure Development is an essential element of workplace safety. Properly designed and implemented LOTO Procedures help to ensure that hazardous sources of energy are effectively isolated from equipment, thus preventing potential injuries or damages.

When creating a LOTO Procedure, it is important to accurately identify all potentially hazardous sources of energy, determine the proper type of lockout device needed for each source, and develop step-by-step instructions on how to properly de-energize and lock out the machine. Additionally, procedures should be regularly reviewed and updated as necessary in order to ensure they remain up-to-date and effective.

By following these steps in the development process, businesses can greatly reduce their risk exposure while also protecting their employees from potential hazards.

For more detailed information, businesses should consult OSHA regulations on LOTO Procedure Development as well as their own corporate safety policies. With the proper development and implementation of LOTO Procedures, businesses can ensure a safe and secure workplace environment while also adhering to all relevant safety regulations.

By investing in the proper protocols and procedures upfront, businesses can make sure that they are providing their employees with the necessary protection against hazardous energy sources. This is an important step toward ensuring a safe work environment for everyone involved.

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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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SMETA Audits

SMETA Audits

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.

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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Waste Disposal Facility Audit Checklist

Waste Disposal Facility Audit Checklist

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

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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Incident Reporting Software

Incident Reporting Software

What is safety incident tracking software?

Safety incident tracking software is an important tool for organizations to maintain safety and security in the workplace. It records and monitors all reports related to safety incidents, providing real-time visibility into potential risks.

This helps organizations identify trends, assess root causes of accidents, and take preventive measures. This tracking software also keeps a record of corrective actions taken by management that can used as a reference for future incidents. This allows for more informed decision making, increased accountability and ultimately an improved safety culture within the organization.

Additionally, it helps organizations comply with applicable safety regulations and standards. Incident tracking software can help organizations create a safer environment, reduce their liabilities, and provide peace of mind to employees.

What are the types of incident reporting software?

Incident reporting software provides organizations with the ability to document and track a workplace incident, helping them investigate issues and prevent future occurrences. It is a valuable tool for businesses of all sizes as it enables them to efficiently manage incidents and reduces the risk of costly liabilities. There are several types of incident reporting software available, each designed to meet specific needs.

These include web-based systems that allow reporting to be done online, desktop versions that can be installed on computers in the workplace, and mobile applications that are accessible on smartphones and tablets. Regardless of the type, all incident reporting software offers features such as customizable forms for recording incidents, tracking information, notifications of new incidents, and reports to analyze data.

What is safety incident reporting tool used for?

A safety incident reporting tool is used to track incidents, collect information about them, and report on the data that has been gathered. This kind of tool enables organizations to quickly identify potential hazards and take corrective action before accidents occur or escalate.

The data gathered by the reporting tool also helps with compliance and provides an audit trail for insurance purposes. Additionally, it can be used to measure the effectiveness of safety measures and provide data for developing better workplace safety initiatives. In short, a safety incident reporting tool is an invaluable tool that helps organizations to monitor and improve safety in their workplaces.

By having access to detailed data about an EHS incident, organizations can also identify trends and common issues that arise, allowing them to take proactive steps to prevent such incidents from occurring in the future.

Additionally, having access to such data can be used by management and safety teams to develop better safety initiatives and ensure that employees are aware of their own responsibilities for maintaining a safe working environment. In short, using a safety incident reporting tool is an invaluable way of helping organizations protect their employees and ensure compliance with relevant regulations.

What is the incident recording system?

The incident recording system is a critical component of workplace safety management. It is used to document incidents, near misses, hazardous conditions or any other type of event that may contribute to an unsafe working environment.

The system allows employers and employees to report details about the workplace incident, such as time and date, location, witnesses involved, type of injury, as well as develop a root cause analysis. This information is then stored in a centralised database, making it easy to quickly review the incident and analyse patterns in order to identify potential hazards.

With such an effective system in place it is easier for employers to prevent future incidents from occurring. Additionally, the system helps ensure that any legal or insurance regulations are followed correctly.

What are the 4 types of incident reports?

  1. Accident Report
  2. Property Damage Report
  3. Security Incident Report
  4. Behavioral Incident Report

Incident reports are written summaries of events that have occurred in a workplace, business, or organization and can be divided into four categories. The first type of incident report is an accident report, which documents any accidents or injuries that occur onsite.

This information can then be used to identify potential risks and take measures to reduce them in the future. The second type is a property damage report, which records any damage to the premises or equipment that has occurred due to dangerous working conditions or negligence. Thirdly, security incident reports document any threats to personnel, data, or assets.

Finally, behavioral incident reports are used to record incidents of verbal abuse, harassment, and other forms of disruptive behavior in the workplace. All four types of incident reports help to create a safe working environment and keep track of any issues that may arise.

Types of workplace incidents:

Workplace incidents are events that occur in the workplace and can have a variety of effects on employees, customers, visitors, and the organization as a whole. Incidents range from minor grievances to serious violations of safety regulations or corporate policies. Common types of workplace incidents include physical assaults, bullying or harassment, property damage, threats or intimidation, fraud and theft, violence or intimidation, and sabotage. It is important for organizations to have policies in place to address each of these incidents appropriately. This ensures that all employees are treated fairly and with respect, while helping to maintain a safe and productive working environment.

Organizations should also have protocols in place for reporting workplace incidents, such as making sure reports are documented accurately and filed promptly with the appropriate authorities. This helps to ensure that incidents are avoidable and can be properly managed if they do occur. By following these protocols, organizations can help to protect both the safety and morale of their employees.

In summary, workplace incidents vary greatly in severity and type, but all are important for organizations to take seriously. Having clear policies and procedures in place is essential to ensure a safe and productive work environment, while also protecting the rights of all employees. It is important for organizations to be vigilant in identifying potential incidents and taking appropriate steps to address them in order to maintain a secure work environment.

What is an incident management software?

A safety incident management software is an application specifically designed to help organizations and businesses respond quickly and efficiently to any type of incidents, such as natural disasters, technical issues, or other emergency situations.

This software simplifies the process of gathering information related to an incident from different sources and aggregating it in a single platform for easier decision-making. Incident management software also provides the necessary tools such as an incident management module, to report incidents, create plans, assign tasks, and track progress towards resolving the incident in a timely manner. Ultimately, this type of software helps businesses investigate incidents and reduce the impact and duration of workplace safety incidents as well as improve overall business continuity.

What is safety incident management?

Safety Incident Management is a process used to identify, assess, and mitigate safety incidents. This process helps organizations protect their personnel by responding quickly and effectively to safety incidents that could potentially cause harm or injury.

It enables organizations to create a comprehensive system for managing injuries, accidents, and other safety-related issues in the workplace through documenting safety incident data. Safety incident management also allows organizations to develop corrective actions and strategies for preventing similar incidents in the future. Overall, it is a critical process that ensures safety and health in the workplace.

What is the ITIL incident management system?

The ITIL incident management system is an effective way to proactively manage service interruptions and minimize their impact. It helps organizations predict, detect, identify, diagnose, and resolve incidents as quickly as possible.

With the help of the ITIL incident management tool, organizations can develop standardized processes for resolving software and hardware incidents in a timely manner. The process includes notifying team members, escalating issues to appropriate personnel, and logging incidents for analysis.

By using the ITIL incident management tool, organizations can ensure that their services are running smoothly and customers receive prompt support when needed.

It also helps organizations develop proactive measures such as training employees on how to use the system and implementing preventive maintenance procedures to reduce service interruptions.

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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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ISO 14001 Checklist

ISO 14001 Checklist

 

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.

 

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Sustainability Software

Sustainability Software

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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Incorporate Sustainability Action Plans Into Your Preconstruction Submittals

Incorporate Sustainability Action Plans Into Your Preconstruction Submittals

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.

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EHS Management Software

EHS Management Software

What does EHS stand for?

EHS stands for Environmental, Health, and Safety. This is an important area of focus for many organizations, as it involves making sure that the environment is safe and healthy for employees to work in. It includes creating policies and procedures related to air quality, safety observations, hazardous materials, fire safety, ergonomics, waste management, electrical safety and more. EHS also ensures that employees are trained and kept up to date on safety protocols in order to reduce the risk of accidents and injuries.

EHS professionals and EHS managers strive to create a safe work place and prevent accidents , which is beneficial for both workers and employers alike. By promoting safe practices, companies can save money by reducing liability risks as well as improve employee morale due to a healthier work place. Ultimately, EHS is a key factor in ensuring the safety and well-being of everyone in the workplace.

What are the responsibilities of EHS department?

EHS stands for Environmental, Health and Safety. It refers to the practices of protecting the environment and ensuring that safe health and safety standards are maintained in a workplace or facility.

EHS involves monitoring air quality, assessing hazardous materials and waste disposal as well as ensuring a safe working environment for employees. It also involves educating employees on safe work practices and ensuring that all laws and regulations are followed.

EHS is an important factor in any workplace, as it ensures that employees are safe, the environment is well protected and health risks minimized. It also helps businesses meet their legal obligations to protect the earth and ensure a safe working environment for its workers.

What is an EHS hazard?

An EHS hazard is any activity or circumstance with the potential to cause harm to people, property, or the environment. These hazards can range from physical dangers such as working with hazardous materials, slips and trips in the workplace, and confined space entry to more intangible risks such as mental health issues due to stress and fatigue.

Identifying EHS hazards and developing strategies to address them is an essential part of any safety management system. It is important to take the time to assess all potential risks and develop a comprehensive safety plan before beginning work in any area. Doing so will help protect employees, customers, and the environment from harm while also keeping fines and costs low.

What is an EHS management system?

An EHS management system (or EMS) is a comprehensive approach to managing an organization’s environmental, health and safety program. It covers the full range of activities necessary to meet legal obligations, improve performance and reduce risks.

An effective EHS management system helps to identify and prioritize areas of risk or concern as well as create consistent processes for dealing with any identified risks. It provides a structured framework for continuous improvement and sets out procedures for monitoring and auditing the system to ensure that it is effective.

Additionally, an EHS management system can be used as a tool to manage regulatory compliance, identify operational efficiencies and support organizational sustainability initiatives. An EHS management system can help businesses move towards a more sustainable and responsible future.

Why is EHS management needed?

EHS management is essential in any institution or organization, regardless of its size or industry. It establishes a safe and healthy work environment while minimizing the risk of injury, illness, and damage to the environment.

EHS management programs seek to identify, manage, and mitigate potential hazards by implementing a systematic approach to safety and health. They ensure compliance with regulatory requirements and help avoid costly fines and legal liabilities.

Furthermore, adopting EHS management practices can boost employee morale, increase productivity, and improve a company’s reputation as a responsible and sustainable business. Organizations that prioritize EHS management can decrease workplace incidents, enhance operational efficiency and performance, and ultimately add significant value to their business.

EHS and The Environment

EHS is a vital component of corporate social responsibility, and it is essential to preserve our natural environment. EHS departments work tirelessly to ensure that buisnesses do not harm the environment through their activities. EHS protects the environment in several ways.

Firstly, it formulates strict guidelines for waste disposal, air quality, and water management, which companies must comply with. Secondly, EHS conducts environmental audits, monitor energy consumption, and tracks carbon emissions to ensure companies adhere to sustainable practices. Furthermore, EHS also collaborates with government agencies to design new environmental policies and keeps abreast of the latest regulatory changes to ensure businesses comply promptly and maintain a clean slate.

Finally, EHS promotes environmental awareness throughout the company and educates employees about sustainable practices that can help save energy and reduce waste. Therefore, EHS is one of the most crucial departments in preserving our planet’s health, and we should support their work.

What Is EHS Software?

EHS software is a technology solution that helps organizations manage workplace safety and reduce environmental risks. The software typically includes modules for occupational health and safety, environmental compliance, incident management, risk assessments, audits, and reporting.

EHS system enables businesses to implement their EHS processes and improve visibility into their EHS performance, allowing them to proactively identify and address potential risks. Additionally, EHS software helps businesses comply with regulations and standards such as OSHA, EPA, and ISO 14001, which can ultimately reduce legal and financial risks.

With the increasing focus on sustainability and corporate social responsibility, EHS system is becoming an essential tool for businesses to ensure they operate ethically and responsibly.

ComplianceQuest and Salesforce – a winning combination

ComplianceQuest is the leading cloud-based enterprise compliance and quality management platform. It offers integrated solutions for a wide range of industries, including healthcare, aerospace, manufacturing and life sciences.

The platform provides tools that streamline processes such as document management, audit tracking, risk assessment and corrective action management. The platform can also be customized to fit any organization’s unique needs. ComplianceQuest is seamlessly integrated with Salesforce, providing customers with an even more powerful solution for meeting their compliance and quality goals.

By leveraging the power of Salesforce, customers can easily access compliant data, improve risk management and optimize operational efficiency. With ComplianceQuest’s integration into Salesforce, organizations have an easy to use, comprehensive tool to ensure compliance and quality in their operations.

How can CQ EHS Management Software help companies?

ComplianceQuest EHS Management Software provides companies with a powerful, easy-to-use platform to help them meet their environmental, health and safety (EHS) goals. Its cloud-based system offers an intuitive user experience and advanced analytics to provide comprehensive visibility into organization’s EHS status.

With ComplianceQuest, companies can create customized dashboards to track data, manage tasks and stay on top of issues in real-time. The software also features automated workflows, notifications and corrective action tracking that help ensure compliance with local, state, national and international regulations.

By using ComplianceQuest EHS Management Software, companies can proactively manage their risks and resources to achieve a better environmental health and safety performance.

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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What is EPA’s General Duty Clause? Where is It?

What is EPA’s General Duty Clause? Where is It?

Does This Apply To You?

iSi can help determine which of these options apply to your facility, and help you make sure you’re on the right track in getting the necessary documentation and processes in place.

In our blog, we’ve looked at OSHA’s General Duty Clause, including issues that are commonly cited under the General Duty Clause.  Did you know that EPA has a General Duty Clause too?

Who Does It Apply To?

The EPA General Duty Clause can be found in the Clean Air Act, Section 112(r)(1).  It states companies that produce, process, handle or store hazardous substances/chemicals have a primary duty to identify release hazards and prevent chemical accidents.

If your company doesn’t fall under EPA’s Risk Management Plan (RMP) requirements, you will fall under EPA’s General Duty Clause.

General Duty Clause vs. RMP

If you produce, process, handle or store hazardous substances/chemicals, you will need to comply with either the EPA General Duty Clause or RMP, based on your operations.

The requirements for RMP can also be found in this same Clean Air Act Section 112(r) as the General Duty Clause, and it also applies to the same types of facilities who use hazardous chemicals.  However, RMP is focused on one or more of 140 targeted toxic or flammable chemicals that have the potential to be released at certain threshold quantities.  Some examples of the 140 chemicals included are ammonia, chlorine, propane, formaldehyde and sulfur dioxide.

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

RMPs must include:

  • Potential effects of a chemical accident
  • Hazard assessments
  • 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.

 What is Required by EPA’s General Duty Clause?

In an EPA inspection, the inspector can ask your company to produce information to show you are complying with the General Duty Clause.  To be compliant, companies are required to address the following 3 topics, with examples for each.

1.  Identify hazards which could occur if an accidental release happens.

  • Identification of related environmental, health and safety hazards
  • Identification of potential release scenarios through experience/industry research, analysis and logic trees, or “What If” brainstorming
  • Determine the consequences in each scenario

2.  Design and maintain a safe facility. (By putting features such as these in place:)

  • Design safety codes
  • Use of less hazardous chemicals when possible
  • Equipment quality control procedures,
  • Using alternate processes
  • Process siting
  • Using safety technology where possible
  • Standard Operating Procedures
  • Employee training
  • Change management
  • Incident investigation programs
  • Self audits
  • Preventative maintenance programs

3.  Determine potential consequences of accidental releases and minimize them.

  • Development of an Emergency Response Plan that contains, at a minimum: anticipated releases, mitigation, notification process to local responders and local responder involvement
  • Coordination with local emergency response officials including the local emergency planning committee
  • Training for “out of the norm” circumstances
  • Periodic exercises using your plan, training, and equipment practicing response, evacuation, sheltering-in-place, and worker’s ability to perform in the event of an emergency

Inspectors will also be looking into the thoroughness of your process hazard analyses, your evaluations, and the elements you’ve put into place, and whether or not they apply to your current operations.

Which One Applies to Your Facility?

Because the RMP is specific to certain chemicals and thresholds, all companies with the potential for accidental chemical releases may not fall under its requirements.  However, if RMP does not apply to your company, then the EPA General Duty Clause will.  

Which one applies to your facility?  Have you completed all the necessary analyses required? Do you have all the programs, processes and training in place?  If the answer to any of these questions is no, then iSi can help.  Contact us today for more information.

Curtis Leiker, CSP
Curtis Leiker, CSP

Contributing:

Curtis Leiker, CSP

Certified Safety Professional |  ISO 45001 and 14001 Lead Auditor

Curtis Leiker, CSP is a project manager at iSi Environmental. Besides assisting companies with ISO 14001 and 45001 implementation, Curtis manages environmental and safety programs, reporting and compliance issues for aviation, general industry and agricultural facilities. He’s able to see the big picture, but focus on the details and enjoys working to solve EHS issues.

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6 Key Steps of an Effective Incident Investigation Process

6 Key Steps of an Effective Incident Investigation Process

Why Conduct Incident Investigations?

When investigating a worksite incident, it is essential to record all findings accurately and thoroughly. This includes documenting the accident scene, identifying any possible witnesses, and interviewing involved parties to verify facts. All of these steps will help employers and workers understand what happened and identify potential hazards in order to prevent future incidents from occurring.

Who should do the investigating?

It is equally important to involve managers and employees in the incident investigation. Managers can provide oversight of the process, as well as draw on their experience to identify potential contributing factors from when the incident occurred. Employees also bring valuable insight – for instance, workers may be able to identify specific unsafe practices or conditions that led up to the incident.

Six steps for successful incident investigation:

The 7 steps of investigation includes:

STEP 1 – IMMEDIATE ACTION

Once the area is safe, first aid and medical care has been given for the people involved and the scene has been preserved, a thorough investigation will begin. Evidence will be collected from multiple sources which may include CCTV tapes, photographs of the scene or other physical evidence such as samples. This evidence must be carefully documented and stored securely in accordance to local laws and regulations.

STEP 2 – PLAN THE INVESTIGATION

It is important to develop a clear plan for investigating any incident. The plan should consider the resources required, who will be involved, and how long it is expected to take. Depending on the severity or complexity of the incident, an investigation team may be necessary in order to ensure that all aspects of the case are thoroughly examined.

An accident investigation is important for any workplace incident, not only for human error but for equipment and management systems errors as well. With a proper investigation, a safety committee will need to involved or established as well as a single investigator.

STEP 3 – DATA COLLECTION

The investigation of any incident requires a thorough analysis of all available information. This might include interviewing witnesses or victims and an injured worker, reviewing documents related to the event, examining equipment or machinery that was involved in the incident and studying the incident scene.

The data collected from these sources can provide invaluable insights into what happened during the incident and help investigators determine the cause. To collect data, comb over every sequence of events and gather information regarding human errors as well as equipment errors. Weather conditions should be documented as well along with safety problems, property damage, serious injury, witness statements, near misses, work environment, other incidents, and other relevant information that will be helpful to the investigation team.

STEP 4 – DATA ANALYSIS

The root cause of an incident is typically the result of multiple failures, decisions, and processes that have been allowed to exist in an organization’s environment. To properly recognize the root cause requires a thorough investigation into the systemic factors at play.

The direct causes are more obvious, but it’s important not to overlook their connections to underlying influences. By looking closely at both direct and underlying causes, it becomes possible to identify where improvement can be made and prevent similar incidents from occurring in the future. In order to understand the data, you’ll need to review records such as inspection reports as well as review all injuries recorded, the me

STEP 5 – CORRECTIVE ACTIONS

Root cause analysis also helps organizations to recognize any potential areas for improvement, ensuring that similar incidents do not happen again in the future. By understanding and addressing the root causes of an incident, organizations can gain greater visibility into their processes and ensure long-term success.

Additionally, significant cost savings can be achieved through effective root cause analysis as it provides a valuable opportunity to review existing processes and address any deficiencies before they become costly later on. Ultimately, when used correctly, root cause analysis can help an organization get ahead of problems before they occur and reduce risks associated with them and other hazards.

Corrective actions might include personal protective equipment changes or updates due to equipment failure. Doing a ‘quick fix’ would be an example of what not to do as a corrective action. Cutting corners can cause repeat incidents and come with serious consequences.

STEP 6 – REPORTING

Once the investigation is concluded and all outstanding issues are closed out, it is important to communicate the findings so that lessons can be shared. In order to do this, organizations should use formal incident investigation reports, alerts, presentations and meeting topics.

Regular safety inspections, regular maintenance, implement corrective actions and a safety program, being sure to follow up with organizational requirements on safety and training both management and employees on safety in incidents are crucial when reporting and maintaining reporting.

Why look for the root cause?

Root Cause Analysis can be used to help organizations recognize and rectify the underlying causes of problems they may be facing. The first step in this process is to identify the negative events that are occurring and determine if any patterns or trends exist among them.

What are the steps involved in investigating an incident?

  • Secure the area
  • Plan the investigation
  • Collect all information
  • Analyze collected data
  • Find the root cause
  • Execute corrective actions
  • Document and share the results

What should I know when making the analysis and recommendations?

If your analysis is just another step of managing incidents. Be sure to allocate the appropriate resources and time to complete a full analysis in these situations:

  • When issues occur or can be expected to occur more than once
  • When an outage has or can affect many users
  • When the system isn’t functioning as designed

What is OSHA Process Safety Management Management of Change?

MOC’s (Management of Change) establish and implement written procedures to manage changes made to process chemicals, technology, equipment, procedures and facilities. OSHA’s Process Safety Management (PSM) standard requires companies to perform MOC’s when changes are made that could affect how safely a process runs.

This procedure should outline all points involved in making changes to the process, such as reviewing safety concerns, assessing risks, identifying potential hazards, selecting appropriate control measures, monitoring results, and updating records.

Which are the three types of MOC?

The three most common types of MOC are administrative, organizational, and technical.

What are the steps of MOC process?

8 Steps to a MOC Process

  1. Identify Proposed Changes.
  2. Risk Assessment.
  3. Determine if Hazards/Risks Can Be Controlled.
  4. Evaluate Making a Change.
  5. Implement Change If Safe.
  6. Pre-Startup Safety Review (PSSR)
  7. Train Workers on Change.
  8. Execute and Monitor Change.

 

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EPA Proposes Rule Expanding Facility Response Plan Requirements

EPA Proposes Rule Expanding Facility Response Plan Requirements

EPA has issued a proposed rule that would require many non-transportation-related facilities to develop a Facility Response Plan under the Clean Water Act, based on planning for worst-case scenario discharges.  This proposed rule significantly increases the number of facilities who may need a Facility Response Plan and increases the number of hazardous substances to be considered when making a compliance determination.

EPA’s goal is to make onshore non-transportation facilities determine if they could reasonably be expected to cause substantial harm to the environment by discharging one of the 296 Clean Water Act hazardous substances into or on navigable waters, the shoreline or exclusive economic zones.  If the facility meets the criteria, then they’ll be required to prepare a Facility Response Plan that plans for worst case scenarios.

This rule is a result of a settlement EPA made in a 2019 lawsuit from the Natural Resources Defense Council and others.  The suit claimed EPA was required, but failed, to make non-transportation-related facilities that could cause substantial harm to plan, prevent, mitigate and respond to worst case spills of hazardous substances.  The consent decree requires EPA to take final action on a rule addressing worst case discharge plans for hazardous substances before September 2022 and this is the result of that.

What Industries are Affected?

The new rule would apply to the following NAICS code groups:

111 Crop Production
115 Support Activities for Agriculture and Forestry
211 Oil and Gas Extraction
212 Mining (except Oil and Gas)
213 Support Activities for Mining
221 Utilities
311 Food Manufacturing
314 Textile Product Mills
321 Wood Product Manufacturing
322 Paper Manufacturing
324 Petroleum and Coal Products Manufacturing
325 Chemical Manufacturing
326 Plastics and Rubber Products Manufacturing
327 Nonmetallic Mineral Product Manufacturing
331 Primary Metal Manufacturing
332 Fabricated Metal Product Manufacturing
333 Machinery Manufacturing
335 Electrical Equipment, Appliance, and Component Manufacturing
336 Transportation Equipment Manufacturing
423 Merchant Wholesalers, Durable Goods
424 Merchant Wholesalers, Nondurable Goods
441 Motor Vehicle and Parts Dealers
444 Building Material and Garden Equipment and Supplies Dealers
447 Gasoline Stations
453 Miscellaneous Store Retailers
488 Support Activities for Transportation
493 Warehousing and Storage
511 Publishing Industries (except internet)
522 Credit Intermediation and Related Activities
562 Waste Management and Remediation Services
611 Educational Services
622 Hospitals
811 Repair and Maintenance
812 Personal and Laundry Services
928 National Security and International Affairs

How Do You Know if It Affects Your Company?

To determine if this applies to your company, there are three criteria to consider.

  1. Maximum Capacities Stored Onsite

Determine if your maximum capacity for any of the 296 Clean Water Act-identified hazardous substances meets or exceeds 10,000 times the reportable quantity in pounds.  The reportable quantities for each hazardous substance are different.  Some may be 5000 lbs. (hydrochloric acid, acetic acid), others may be 1000 lbs. (nitric acid, phenol), some may be 100 lbs. (hydrogen sulfide, formaldehyde), others may be 10 lbs. (benzene, nitrogen dioxide, sodium) and some may be 1 lb. (PCBs, arsenic, diazinon).

  1. Location

Next, determine if your facility is one half mile of a navigable water or conveyance to a navigable water.  The definition of a navigable water has been under debate for a number of years and has changed between the different Presidential administrations.

  1. Substantial Harm Criteria

Last, do you meet any of the substantial harm criteria.  That is, will you:

  • Do you have the ability to adversely impact a public water system?
  • Could you cause injury to fish, wildlife and sensitive environments?
  • Do you have the ability to cause injury to public receptors?
  • Have you had a reportable discharge of a Clean Water Act hazardous substance within the past 5 years?

If you meet the substantial harm criteria, you would need to submit your Facility Response Plan to the EPA.  Existing facilities that meet the criteria on the effective date of the rule would have to submit a Facility Response Plan within 12 months.

What is a Facility Response Plan (aka, an FRP)?

FRPs are required per 40 CFR 112.  Current criteria says if you have over 42,000 gallons of oils and are transferring them over water to/from vessels, or if you have over 1,000,000 gallons and meet other certain criteria, you are required to have one. Facility Response Plans requirements are from the Federal Water Pollution Control Act.

Public Comment

EPA is taking public comments on the proposed rule until May 27, 2022.  More information, including links to the public comment site can be found HERE.

We Can Help You Determine if This Will Apply To You

iSi can help you determined if this will apply to you, and then help prepare, review and update Facility Response Plans for your facility.  We also can do the training required for it.  Contact us today!

Questions?

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Sustainability Consulting for the 21st Century

Sustainability Consulting for the 21st Century

The modern world is a sustainable one. It’s time for your business to join the ranks of those who are making a difference.

Sustainability has become one of the most important topics of our time. As the world becomes more and more aware of the environmental, social, and economic challenges we face, more and more businesses are looking for ways to operate in a more sustainable way.

That’s where sustainability consulting comes in. A sustainability consultant helps businesses identify opportunities to operate in a more sustainable way. This can mean anything from reducing energy consumption to increasing employee engagement in sustainability goals.

Sustainability consultants come from a variety of backgrounds, but all share a common goal: to help businesses move towards a more sustainable future with sustainability services.

The good news is that sustainability consulting is one of the fastest growing industries in North America and the world. The bad news is that it can be hard to know where to start when it comes to finding a sustainability consultant that’s right for your business.

Here are four tips to help you find the right sustainability consultant for your business:

1. Define your sustainability goals and ESG strategy.

What does your business want to achieve by working with a sustainability consultant? Do you want to reduce your carbon footprint in your global business? Develop more robust sustainability strategies? Achieve sustainable development goals? Incorporate sustainability solutions and a sustainable infrastructure into your business strategy? Improve employee engagement? Need risk management? Find ways to save money.

Once you know what you want to achieve, you can start looking for consulting firms that specialize in those areas.

2. Identify a budget.

Do your sustainability ambitions match resources available for the project? Does the ESG (Environmental Social and Governance) strategy align with your corporate growth strategy?

It is recommended to present a sustainability strategy internally, that outlines tiers of investment and the types of sustainability performance to be expected per expenditure.

3. Do your research.

Do a deep dive in the sustainability consulting services universe. Once you’ve identified some consulting firms that might be a good fit, take some time to learn about their backgrounds and experience and nail it down to your favorite consulting firm.

How long have they been working in a sustainable business? What are some of the clients they’ve worked with? What do other people say about them? Top consulting firms offer diverse corporate responsibility solutions and professional services across a wide swathe of industry sectors.

4. Ask for recommendations.

Talk to other businesses in your industry and see if they’ve worked with any sustainability consulting firms that they would recommend. If you know someone who works in sustainable business, ask them for their thoughts on different consultants.

The best way to find a good consultant in the large world of the consulting industry is through word-of-mouth from people who have worked with them before.

A global management consultancy will have the general pulse on corporate social responsibility. Top sustainability consulting firms will be a global leader in change management and integrated business planning.

The best ones possess deep expertise in the management of business risk and climate risk, while working with you to embed sustainability into your culture.

These days, there’s no excuse for not being sustainable, not manage risk, and not create sustainable business models.

Future leaders and businesses that don’t take steps to operate sustainably will not only be missing out on opportunities and losing business value, but will also be left behind as society progresses towards a more sustainable future.

These can be complex problems. Sustainability consulting is one of the best ways for businesses to make sure they’re operating sustainably and making a positive impact measurement on the world around them.

iSi Environmental is a leading provider of environmental consulting and management consulting services in the United States and we are committed to protecting the planet and its inhabitants with the skills and knowledge of our people. With us you get long term value.

Senior Executives and Sustainability Teams turn to us when:

  • Their team is short on time and resources to achieve organizational sustainability strategy
  • They need hands-on implementation of new compliance processes
  • They need to integrate sustainability at multiple locations
  • Also turn to us when looking to roll local best practices into a global corporate system

Need Assistance?

What can iSi’s team of EHS Consultants do for you?  Contact us!

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The Top 4 Facility Response Plan Issues Found by EPA

The Top 4 Facility Response Plan Issues Found by EPA

EPA has reviewed inspection data from its regional offices to get an idea of the most common Facility Response Plan and SPCC (Spill Prevention, Control and Countermeasures) Plan deficiencies.  The goal of the review was to help EPA determine how clear their rules were to help companies comply with the regulations.  [Check out the SPCC Plan deficiencies here.]

What is a Facility Response Plan (aka, an FRP)?

Facility response plans are required per 40 CFR 112. If you have over 42,000 gallons of oils and are transferring them over water to/from vessels, or if you have over 1,000,000 gallons and meet certain criteria, you are required to have a Facility Response Plan. Both the SPCC Plan and Facility Response Plan are from the Federal Water Pollution Control Act.

EPA’s Review

The data was reviewed for companies who also had both Facility Response Plans and SPCC Plans, with a preference for companies with higher oil storage capacity.  The Facility Response Plans facilities had an average aggregate oil storage capacity of 69,000 to 857 million gallons of oil, with a worse case scenario discharge planning volume of 94,000 to 20 million gallons.  EPA found an average of 4 issues per plan.

Top 4 Facility Response Plan Deficiencies (in Order)

  1. Diagrams (1.9) – 31 of the 55 had this deficiency
    • This includes site plans, evacuation plans and drainage diagrams.
  2. Discharge Scenarios (1.5)
    • This includes discussion and plans for worse-case discharge.
  3. Vulnerability Analysis; Hazard Evaluation (1.4. 2 and 1.4)
    • This would be spill history and analysis of discharge potential.
  4. Plan Implementation  (1.7)
    • This would be a description of containment and drainage planning, disposal plans and response resources.

Other Issues Found

  • Lack of details about response equipment. (1.3, 1.3.2)
  • Companies didn’t include key information from their Emergency Response Action Plans (ERAPs) (1.1)
  • Not conducting required preparedness drills and exercises (1.8)
  • Not training personnel on appropriate oil spill response measures.

Do you have any of these issues with your own Facility Response Plan? Are you required to have an FRP? We can help! We can review your plan for compliance to these issues, prepare updates, or provide the required training or scenarios you need to conduct to your employees. Contact us today!

How Can We Help?

iSi can prepare, review and update Facility Response Plans for your facility.  We also can do the training required for it.  Contact us today!

Questions?

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EPA Names Most Common SPCC Plan Deficiencies – Do You Have Any of These?

EPA Names Most Common SPCC Plan Deficiencies – Do You Have Any of These?

EPA recently reviewed inspection data from its regional offices to get an idea of the most common SPCC (Spill Prevention, Control and Countermeasures) Plan deficiencies.  The goal of the review was to help EPA determine how clear their rules were to help companies comply with the regulations.

The data was reviewed for companies who had SPCC Plan issues, with a preference for companies with higher oil storage capacity and who also had to have Facility Response Plans (FRPs) onsite as well.  Inspection data was reviewed for 120 companies with oil storage capacity between 4,000 gallons and 857,000,000 gallons.

Of those, 10 companies didn’t have an SPCC Plan.  Of the remaining, they found that the companies averaged 4 issues with their plans.

Top 9 SPCC Plan Deficiencies (in Order)

  • Plan Content, Certifications & Reviews (112.3, 112.5, 112.7) – 119 of the 120 had this deficiency
  • General Secondary Containment (112.7)
  • Testing and Inspection: Integrity Testing (112.8, 112.12)
  • Sized Secondary Containment (112.8, 112.9, 112.12)
  • Drainage (112.8)
  • Piping: General (112.8)
  • Piping: Inspections (112.8, 112.9)
  • Discharge Prediction (112.7)
  • PE Certification (112.3)

Some examples of these include:

  • Inadequate or no documentation of the required 5-year review of the plan;
  • Failure to address required containment for piping;
  • Failure to address integrity testing of bulk storage containers;
  • Failure to demonstrate that secondary containment met the requisite size of design requirements; and,
  • Failure to provide procedures for controlling stormwater discharges from diked areas.

Do you have these issues with your own SPCC plan?   Are you required to have an SPCC Plan?  Check out our blog about SPCC plans, or contact us today to help.  We can review your plan for compliance to these issues, conduct the required 5-year update, or provide the required training you need to conduct to your employees.  Contact us today!

Can We Help?

iSi can prepare, review and update SPCC Plans for your facility.  We also can do the training required for it.  Contact us today! 

Questions?

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RCRA Air:  What Air Regulations are in the Hazardous Waste Standards?

RCRA Air: What Air Regulations are in the Hazardous Waste Standards?

In our blog article about EPA’s compliance initiatives, EPA 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.  So, what are the RCRA air requirements, and who is affected by them?

RCRA air regulations pertain to organic air emissions from equipment used for hazardous waste.  There are 3 different standards – Subparts AA, BB and CC – and each are specific to the type of equipment being used. 

Subpart AA deals with process vents used for treating/recycling hazardous waste, Subpart BB deals with equipment leaks and Subpart CC deals with tanks, containers and surface impoundments. All Subparts are focused on controlling emissions from the specific Subpart processes.

Subpart AA

Some equipment examples for this Subpart would include vents associated with solvent extraction, air stripping, steam stripping, thin-film evaporation, and distillation and fractionation columns. 

To be regulated, the unit must:

  • Be permitted or in interim status;
  • Be a recycling unit at a facility that has a RCRA permit or is operating under an interim status due to some other hazardous waste management operation (such as a RCRA-permitted storage tank); or,
  • Be a 90-day container or tank.
  • The hazardous waste being treated or recycled must contain at least 10 ppmw total organics.

Exemptions:

  • The recycling unit is at a facility that has no RCRA permit and is not operating under an interim status; or,
  • Your facility is equipped and operating with air emissions controls complying with other air regulations (CAA, NSPS, NESHAP, MACT) in 40 CFR Parts 60, 61 or 63 for each affected process vent.

Requirements:

If this regulation applies to you, then you’re required to first determine the emissions from all of those vents and if it’s less than 3 lbs/hour and 3.1 tons/year, no controls are required.  However, if it’s that rate or more, your facility must either find a way to reduce those emissions or use control devices that will reduce total organic emissions from all affected process vents by 95%. 

Subpart BB

This subpart is about equipment found in hazardous waste pipelines or the ancillary equipment associated with a hazardous waste tank.  These can be valves, pumps, compressors, pressure-relief devices, flanges, connectors, sampling connection systems or open-ended lines/valves.

To be regulated, the equipment must:

  • Be part of a permitted or in interim status unit;
  • Be part of a recycling unit at a facility that has a RCRA permit or is operating under an interim status due to some other hazardous waste management operation (such as a RCRA-permitted storage tank); or,
  • Be part of a 90-day container or tank.
  • The hazardous waste in the equipment must contain at least 10% total organics by weight.
  • The equipment must be in contact with or contain the hazardous waste for at least 300-hours per calendar year.

Exemptions:

  • The recycling unit is at a facility that has no RCRA permit and is not operating under an interim status;
  • The equipment is operated, monitored or repaired in accordance with air regulations (CAA, NSPS, NESHAP, MACT) for fugitive equipment leaks from 40 CFR Part 60, 61 or 63; or,
  • The equipment is in vacuum service because leaks would go back into the equipment.
  • If the facility can document that the equipment is flushed out between campaigns so that it contacts or contains the hazardous waste for less than 300-hours per calendar year, it is exempt.

Requirements:

If this regulation applies to your company, you’ll be required to implement an LDAR program (Leak Detection and Repair) for the applicable equipment.  LDAR programs are a significant effort and have their own design standards, tagging, and recordkeeping, reporting, inspection and monitoring requirements.

Subpart CC

This regulation applies to hazardous waste tanks, containers and surface impoundments (lagoons, holding/storage pits, ponds, etc).

To be regulated, the equipment must:

  • Be part of a permitted or in interim status unit; or,
  • Be a 90-day container or tank.

Units must receive hazardous waste containing greater than or equal to 500 ppmw volatile organics at the point of waste origination.  For generators, the point of origination is the same as the point of generation.  For TSDF facilities, the point of origination is where the owner accepts delivery/takes possession of hazardous waste.

Exemptions:

  • Satellite accumulation containers;
  • Small Quantity Generators’ 180/270 day tanks and containers;
  • Containers with a design capacity of less than or equal to 26.4 gallons;
  • Units used solely for the onsite treatment or storage of remediation wastes under state or RCRA corrective action or CERCLA;
  • Units not subject to substantive RCRA standards, including wastewater treatment units, elementary neutralization units, immediate response units and totally enclosed treatment units;
  • Units that receive radioactive mixed wastes; or,
  • Equipment with air emissions controls in accordance with air regulations (CAA, NSPS, NESHAP, MACT) in 40 CFR Part 60, 61 or 63.

Requirements:

If this regulation applies to your company, you’ll first need to determine the volatile organic concentration for every hazardous waste managed in one of these units.  If the concentration of every waste entering a unit is less than 500 ppmw, no emission controls will be required. 

Even if your tank contains less than 500 ppmw, if anywhere along the way to the tank from point of origination is 500 ppmw or more, you’ll need the emissions controls.

Tanks

For low vapor pressure wastes, a tank with a fixed roof with no gaps or openings between the roof edge and tank wall can be used.  For all other wastes, there are several options (floating roof, fixed roof with control device, enclosure vented to enclosed combustion device or pressurized tank). Control devices can be a flare or carbon adsorbers.

Containers

There are 3 levels of standards, based on container size.  Level 1 is low vapor pressure wastes in small capacity containers (26-121 gal), 55 gal drums, roll off boxes for soil, and containers greater than 121 gal.  For this level you must use DOT containers, they must have tight fitting covers with no visible holes or gaps, and they need to be closed.

Level 2 is for more volatile wastes in greater than 121 gal containers.  An example would be a tank truck with spent solvent. Here, use DOT containers, they must be closed having no detectable organic emissions, and you must prove they’re vapor tight on an annual basis.

Level 3 is where hazardous waste is being stabilized. They must be connected to a closed vent system to a control device and meet special requirements for being managed in an enclosure.

Surface Impoundments

Emission controls for surface impoundments must have an air-supported or rigid cover that’s vented to a control device or be an HDPE or similar floating membrane with a minimum thickness of 2.5 mm.

Does This Apply to You?

iSi can help you determine if you’re subject to RCRA Air regulations, and which Subpart you’re required to follow.  Contact us today for a price quote!

Do You Need to Comply With This?

Is this regulation something you need to be complying with?  iSi’s consultants can help you figure that out, and help you determine if you qualify for one of the exemptions.

Questions?

Does this apply to your company?  Do you have questions?  Contact us!

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Sarah Winfrey
Sarah Winfrey

Contributing:

Bria Weast

Environmental and Safety Consulting Manager

A member of our Consulting Services division, Bria works with client facilities for annual environmental reporting and day-to-day environmental compliance assistance.  She also manages iSi project managers.  Bria has conducted well over 100 Phase I environmental site assessments for iSi and is one of the trainers for our Hazardous Waste Management class.

Email  |  LinkedIn

EPA Discusses Current Compliance, Enforcement Priorities and Initiatives

EPA Discusses Current Compliance, Enforcement Priorities and Initiatives

At the recent KDHE Environmental Conference, Dave Cozad, Director of the Enforcement and Compliance Assurance Division with Region VII EPA gave an update outlining EPA’s upcoming compliance and enforcement priorities.

Compliance Inspections & Public Posting of Reports

EPA was scheduled to go back out to do more onsite inspections, but the resurgence of COVID put a delay on that.  For the past year they had been doing some announced remote inspections to evaluate compliance.  However, unannounced inspections will eventually resume.  Inspectors will have Smart Tables preloaded before they go onsite.  Their goal is for the report of findings be available in less than 60 days after inspection.

One important comment made was that EPA is working on implementing the public posting of inspection reports.  That is, what is found at your site during an inspection and what’s on your report will eventually be available for anyone to see.

Executive Orders Provide Roadmap

EPA has been given several directives through Executive Orders (EOs), and the issues EPA will focus on will very much be related to these.

These EOs include the following guidelines:

  • Hold polluters accountable, including those who disproportionately harm communities of color and low-income communities.
  • Strengthen and enforce environmental violations with disproportionate impact on underserved communities
  • Create a community notification program to monitor and provide real-time data to the public on current environmental pollution
  • Strengthen enforcement in communities with environmental justice concerns
  • Tackle climate change and enforcement of climate change-related issues

The term “environmental justice”, or EJ, goes along with these directives and will be applied to daily decision making.  To meet the directives, EPA will be spending more of their time looking at regulated industries in these underserved communities and will be strengthening enforcement of violations for cornerstone environmental statutes and civil laws.  Thus, the number of air, wastewater, and hazardous waste inspections in these areas will increase and items such as air monitoring results may be posted for the public to review.

EPA plans on going into these areas and speaking with the people about their enforcement case concerns rather than just determining themselves what EPA thinks they need, as they historically have done.

In the area of climate change, they’ll be targeting cases with greenhouse gas-related requirements and a ban on importing hydrofluorocarbons.  Climate-focused mitigation and resilience will be a part of the efforts.  For example, taking a look at situations like floods where there are chemical plants in floodplains or where sewer systems could have major overflows.

National Compliance Initiatives

National Compliance Initiatives are set goals that follow a certain process and include the states. Because of this, they  are much harder to change from administration to administration.  Some of these have been initiatives for the past 2 years, but give an idea of certain targets of inspections.

RCRA Air

This is hazardous waste emissions via air, where there are regulations related to the quantity of VOCs emitted.  This is for facilities with tanks, surface impoundments and valves.  Inspectors have started making a concerted effort to look at these during their inspections and it’s one of the lesser items focused on by some facilities. Right now 30% of facilities being inspected are not complying with this part of the regulation, and the fines can be $255,000.  What is RCRA Air? Learn more here.

Chemical Accident Reduction – RMP

EPA will be checking that Risk Management Plans are in place and implemented properly for those that are required to have them.  This is related to Clean Air Act section 112(r) for the prevention of accidental releases of chemicals.  Facilities that store and handle large quantities of listed regulated substance in a process, over certain threshold amounts.  EPA inspection data is showing that 50-75% of facilities are not complying fully with RMP.

Creating Cleaner Air for Communities and Drinking Water

We listed these 2 initiatives together because they will be treated similarly under the umbrella of EJ.  Making air and water cleaner has always been a goal, but considering the EOs, a focus on issues with public water systems, lead-based paint and air emissions from inner-city factories helps EPA accomplish more than one goal.  Plus those kinds of issues will affect a large amount of people at once. It becomes a more bang for their buck item, so to speak.

Mobile Source Aftermarket Defeat Devices

EPA is looking to conduct enforcement on companies who make, develop and sell aftermarket devices that bypass, defeat or renders inoperative any emission control device in order to enhance engine performance.  Examples would be plates that partially block a portion of exhaust gas stream, kits that enable the removal of the catalytic converter or the diesel particulate filter or tuners that stop signals from going to the   vehicle’s computer that usually would turn on the check engine light or put the vehicle in limp mode.  EPA’s news updates have been announcing fines for a number of companies recently for violations so this initiative is up and running.

NPDES Permit Compliance

EPA is looking to reduce the significant non-compliance they’re seeing with National Pollutant Discharge Elimination System (NPDES) permits. In an EPA memo to regional administrators regarding this initiative, they identified they wanted to reduce the non­compliance baseline rate by 50% by the end of FY 2022, while assuring that the worst violators are timely and appropriately addressed.

EPA wants its regions and states to work together.  Each state’s rate will be looked at as will its approaches (past and future) to reduce the non-compliance rate, the completeness and accuracy of its compliance data (and why it’s wrong/missing), and how and when they plan on addressing the more severe non-compliance violations.

Over 60% of the non-compliance is attributed to “non-receipt” of Discharge Monitoring Reports (DMRs).  Interestingly, EPA speculates that some of this isn’t all about companies not turning in their reports, but the way the states communicate or handle getting the information into the EPA’s tracking system.  However, make sure you get your DMRs in as this is something that’s on the radar.

If any of these initiatives can be tied back to those EOs, then all the better for EPA and their compliance goals.  For example, in the press release announcing a settlement for one of the companies found selling mobile defeat devices, part of the settlement was for the company to “…replace 3 school busses in a Columbus, OH in the areas of environmental justice concern.” In that same release, the regional administrator said she was “…pleased that the settlement will reduce the impact of pollution in already overburdened neighborhoods.”

EJScreen

EPA has a screening and mapping tool to help them identify areas that may be candidates for environmental justice-related consideration, outreach or programs. EJScreen is considered to be “…a consistent tool that can be used by EPA, its governmental partners and the public to understand environmental and demographical characteristics of locations throughout the United States.”

EJScreen was actually developed in 2010 as a response to an Executive Order by the Clinton Administration.  It is geared to help users identify areas with minority/low income populations, potential environmental quality issues and places where environmental and demographical indicators are greater than usual.  EPA plans to use EJScreen to implement permitting, enforcement, compliance, outreach and enhance geographically-based initiatives.  Facilities who lie within an EJScreen target area will be the ones who will receive the most inspections.

Check out EJScreen at: https://ejscreen.epa.gov/mapper/.

Other Areas

Other compliance hot topic/focus areas mentioned on EPA’s radar include:

  • Children’s health, mainly related to lead
  • Generators without proper status/notifications
  • Asphalt plants using mine tailings from CERCLA sites
  • PFAS
  • “Recycling” facilities
  • Coal combustion residuals
  • Potential return of supplemental environmental projects
  • EPA budget and staffing

Do you see any issues here that may be affecting your company?  Or are you unsure which ones may affect you?  Contact iSi today for EPA and state environmental compliance assistance and advice!

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Sarah Winfrey
Sarah Winfrey

Contributing:

Bria Weast

Environmental and Safety Consulting Manager

A member of our Consulting Services division, Bria works with client facilities for annual environmental reporting and day-to-day environmental compliance assistance.  She also manages iSi project managers.  Bria has conducted well over 100 Phase I environmental site assessments for iSi and is one of the trainers for our Hazardous Waste Management class.

Email  |  LinkedIn

EPA’s Changes to TRI Reporting:  What to Know Before the July 1 Due Date

EPA’s Changes to TRI Reporting: What to Know Before the July 1 Due Date

EPA has made some updates, changes and additions to their Toxic Release Inventory (TRI) reporting.  Their focus on environmental justice is evident in many of these changes.

Because the TRI is used as a mechanism to publicly report businesses’ chemical and release information, changes and additions to the TRI is a logical place to start when it comes to EJ’s goal of transparency and giving citizens equal access to information to make decisions on where they live and work.  Thus, this is an easy place to start, and where we may find more changes throughout the year.

TRI reports, aka Form R, also aka SARA 313 reports are due July 1.

What’s Environmental Justice?

EPA defines EJ as:

“The fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income, with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies. This goal will be achieved when everyone enjoys:

  • The same degree of protection from environmental and health hazards, and
  • Equal access to the decision-making process to have a healthy environment in which to live, learn, and work.”

EPA has an entire section dedicated to EJ on its website.  They even have a mapping and search tool called EJSCREEN that combines environmental and demographic indicators in maps and reports.

Changes in Some de Minimis Percentages

EPCRA Section 313 and chemical categories are subject to a 1% de minimis concentration unless the substance has been named a carcinogen or potential carcinogen. That is, when you’re determining thresholds of chemicals, some chemicals can be exempt from reporting if you have minimal concentrations of non-Persistent Bioaccumulative Toxic (PBT) chemicals in mixtures.  This is called a de minimis exemption.  The following chemicals have had their de minimis percentages altered from 1% to 0.1% because they are now OSHA carcinogens:

Reporting Year 2020 (due July 1, 2021)

  • Pyridine
  • Methyl acrylate
  • Quinoline
  • Vinylidene chloride

Were Changed for Reporting Year 2019 (due last year)

  • N,N dimethylformamide (CAS 62-12-2)
  • 2-mercaptobenzothiazole (CAS 149-30-4)
  • Molybdenum trioxide (CAS 1313-27-5)

Supplier Notifications

Don’t forget that companies who process or manufacture TRI-listed 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“?

Per- and Polyfluoroalkyl Substances (PFAS) Reporting

The 2020 National Defense Authorization Act requires a PFAS to be added to TRI when it meets a certain criteria.  For reporting year 2020, EPA added 172 PFAS chemicals.  The threshold for those is 100 pounds, manufactured, processed or otherwise used.  If you use any of these chemicals, these should be included in your reporting year 2020 reports, due July 1, 2021.

For the 172 PFAS chemicals, the de minimis concentration for perfluorooctanoic acid (PFOA) is 0.1%.  For all other PFAS chemicals, the de minimis level is 1%.

So far for the 2021 reporting year, EPA has added three new PFAS: perfluorooctyl iodide, potassium perfluorooctanoate and silver(I) perfluorooctanoate.  These also have the same threshold of 100 pounds. EPA will be adding more as they come along.  EPA is anticipating that perfluorobutane sulfonic acid (PFBS) will be the next one added.

For more information about the 172 PFAS chemicals, go to EPA’s site here.  For guidance on PFAS reporting, you can visit the special PFAS guidance here.

PFAS Fire Suppression Foam

Fire suppression aqueous film forming foam (AFFF) is a common PFAS chemical.

For this chemical, if it is released for system testing, training or to suppress a fire, it’s considered otherwise use and needs to be reported on your TRI.

If it’s not used onsite, but just stored there, it’s not considered an activity and does not need to be reported.  Only when it’s released from a fire suppression system is it considered an activity (that is, manufacture, process or otherwise).

If you use the fire foam offsite it’s not included in the threshold.

TSCA Work Plan and High-Priority Chemicals

EPA would like to add chemicals that are listed on the Toxic Substances Control Act’s (TSCA) Work Plan.  The TSCA Work Plan is a list of 90 chemicals under further assessment by EPA.  Those chemicals are chosen based on their potential for high hazard and exposure. As an example, the first 10 of those 90 chemicals currently under review include:

  • 1,4-Dioxane
  • 1-Bromopropane
  • Asbestos
  • Carbon Tetrachloride
  • Cyclic Aliphatic Bromide Cluster
  • Methylene Chloride
  • N-methylpyrrolidone
  • Pigment Violet 29
  • Tetrachloroethylene, aka Perchloroethylene
  • Trichloroethylene

EPA would also like to take a look at adding other chemicals from a list of 25 chemicals suggested for addition by the Toxics Reduction Institute in Massachusetts.  The group petitioned EPA to add 25 more chemicals to TRI.  EPA is evaluating those to determine if they meet the EPCRA 313(d)(2) criteria.   Some examples of these include:

  • 1, 2, 3-Trichlorobenzene
  • 1,3-Dichloro-2-propanol
  • n-Propyl Bromide (1-Bromopropane)
  • Formamide
  • 1,1’-Azobis (Formamide)
  • Nitrilotriacetic Acid, Trisodium Salt
  • N, Ndimethylacetamide
  • Hexahydrophthalic Anhydride

Facilities Added to TRI Reporting Requirements

Natural Gas Processing Facilities

Natural gas facilities will be an included type of facility on the Emergency Planning and Community Right to Know Act (EPCRA) Section 313.  Thus, those facilities will need to submit reports to TRI.  EPA wants to make sure natural gas processors’ chemical releases and waste management activities with TRI-listed chemicals are available to the public because millions of people live within 30 miles of at least one natural gas processing facility.

Contract Sterilization Facilities

Further reporting of ethylene oxide (EtO) will be required on the TRI.  Specifically, contract sterilization facilities have been called out as types of facilities this will affect.  EtO is used to sterilize medical devices and to make certain chemicals.  Contract sterilization facilities currently are not required to report, but they will be required in the future.  EPA says that these facilities often are located in areas with environmental justice issues, affecting those who work there and live around them.  Adding these facilities to the list will give more information about EtO releases and allow EPA to respond to the health and environmental threats they cause.

Adding More TRI Tools for the Public

EPA wants to make TRI data even more useful and accessible for the public.  As a result, they want to make the following additions:

  • Add a demographic profile section to TRI so that you can search by income profile and race, similar to what’s available on EJSCREEN;
  • Launch a Spanish version of the TRI; and,
  • Promote the Pollution Prevention (P2) information that companies are required to include in their TRI reports. EPA hopes that this will encourage the community to work with the TRI facilities to increase their P2 efforts and reduce releases in the community.

There are currently no timetables for completion of these new goals and additions.  iSi will keep you updated as we see changes and additions finalized and added to TRI or EPCRA.

Amanda Scheufler of iSi Environmental
Amanda Scheufler of iSi Environmental

Contributing:

Amanda Scheufler, CHMM

Consulting Services Director

Amanda’s experience and training encompasses all things environmental compliance and environmental auditing.  Her specialties include environmental reporting, hazardous waste management, air compliance, Storm Water Pollution Prevention, SPCC, and Facility Response Plans.  Managing iSi's Consulting Services division, Amanda has served as an onsite safety and environmental manager for several industrial facilities through iSi's EHS COOP program and she also teaches part of iSi's Hazardous Waste Management class.

Email  |  LinkedIn

A Look Into the Biden Administration’s Environmental Priorities

A Look Into the Biden Administration’s Environmental Priorities

New year, new president, and a new push on policies. Trying to guess what will happen for the next four years into any new Administration is like trying to figure out when it will actually rain here in the Midwest. But, just like the assistance of a meteorologist, we can start to predict what we will see with the help of folks who understand and specialize in public policy.  

At the head of the Biden EPA is Michael Regan. A 20-year experienced environmental regulator, he was the head of the North Carolina Department of Environmental Quality and returns to the White House from formerly being an air quality specialist in the Clinton EPA.

Here are a few things to look for from the Biden/Regan team:

Environmental Justice (EJ)

While there are still questions bouncing around about how the Administration will carry out EJ, facilities can get ahead of the game and be prepared for what is to come. One of the biggest items that will be coming out of EJ is communities having their voices heard in environmental regulation. Something companies can start doing to prepare for this is reaching out to the communities where their facilities are located at. We understand the data we collect and how we collect it, but does the public understand it? Now is the time to educate the community you share a fence line with.

There are two major legislative proposals to keep an eye on. The Environmental Justice Mapping and Data Collection Act of 2021 will create a tool built upon the EPA’s EJScreen to identify demographic factors, environmental problems, socioeconomic circumstances and public health concerns. This data collected will help build maps of communities that are affected the most. This will help the Administration to direct appropriate funds to those communities.

Companies should be looking at the EPA’s EJScreen tool. It interprets and shows environmental indicators and demographic indicators. It is used for informing outreach and engagement practices, as well as permitting and compliance implementation, just to name a few.

The Environmental Justice for All Act will establish EJ requirements, advisory bodies and programs to address the environmental effects on human health for low-income communities. It will also provide the establishment of the Interagency Working Group on Environmental Justice Compliance.

More Inspectors on the Ground

With COVID-19, we saw fewer boots on the ground and the number of virtual inspections and audits go up throughout facilities. With vaccines rolling out and the country starting to open back up, there is going to be a drive to get inspectors back on the ground. Now is the time to go over your facility’s reporting to make sure it is accurate and to re-evaluate your risk assessment plans and make sure your facility complies with all regulations.   

Waters of the United States (WOTUS)

WOTUS is already under review for this Administration. We can expect to see extreme discussion on this since having to define WOTUS is difficult, as it is controversial.  Multiple states, tribes and environmental groups pushed back on the Trump Administration’s Navigable Waters Protection Rule, so we can speculate that the Biden Administration will want to expand the definition and scope and go for a broader rule to replace it.

Per- and polyfluoroalkyl substances (PFAS)

Expect to see the enforcement of PFAS being talked about, as well. Some questions are if the Biden Administration will use the All-of-Government approach like we are seeing in climate change, if they will revisit the 70 ppt LHA for drinking water and if the remediation of PFAS will be listed as a hazardous waste under RCRA or CERCLA. States are also getting involved with PFAS. There will be multiple legislation pieces floating around on both the federal and state level.  Regan is committed to making PFAS a “top priority” for this team and he mentioned in his Senate confirmation that part of this approach will include pursuing discharge limits and water quality values.

Need Any Help?

If you need help with getting your facility in compliance, iSi has multiple project managers that specialize in doing third-party compliance audits and reporting.  Contact us today!

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Sarah Winfrey
Sarah Winfrey

Contributing:

Sarah Winfrey

Sales Development Representative

Sarah works with our Business Development and Marketing team, assisting with client and internal communications, pricing proposals, customer support and sales efforts.  She also maintains a number of iSi's contractor registrations and assists with industry and regulations research.

Email  |  LinkedIn

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