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How to Conduct a World Class Environmental Audit

  1. How to Conduct a World Class Environmental Audit Presented by Gary Vegh
  2. To Start  Show of hands for: – Health & Safety Professionals? – Environmental Professionals? – If Health & Safety a bigger priority at your company? – Anyone who finds Environmental more complicated?
  3. Environmental vs. Health & Safety  Environmental management – Requires more time/task – Harder to understand – Often like “a different language”  Fire extinguisher training is easy.  Air emissions compliance is not.
  4. What would you classify as a World Class Environmental Audit?
  5. “When auditors compliment you on your record keeping”
  6. Change Your Viewpoint. Environmental = Chemical Safety
  7. How to Re-frame “Environmental” For Success  And it’s simply another form of H&S – It’s designed to keep people safe – Key environmental reports designed for safety
  8. Key Environmental Reports  Annual Air Emissions Inventory – Like your tax return – Keeping your workers and your local population safe by tracking air quality.  Tier II report – For emergency responders. Profile of hazardous substances on site.  Toxic Release Inventory (TRI) – Materials processed at your facility. Releases to air, water & land.  Department of Homeland Security (DHS) Chemicals of Interest – Tracking DHS chemical list for anti-terrorism laws.  Biennial hazardous waste (RCRA) – Tracking hazardous waste movement from your facility
  9. How to Approach Environmental  Ultimate goals: – Reduce time required for reporting – Get back to H&S issues – Achieve accuracy
  10. What are Accurate Reports For?  Government needs accurate data: – Public’s right to know – Regulations are not static - EPA is mandated to revisit regulations every 5 years – International commitments
  11. How Accuracy Can Suffer  Lack of time or commitment – Throwing out numbers – Not necessarily accurate – Signing officer doesn’t know what he’s signing  Someone is always left holding the bag!
  12. Systems: Backbone of Management “You don’t want to be the machine. You want to own the machine”
  13. Why Should YOU Care?  Another show of hands: – If you consider yourself a “systems improvement person”?  Question: – If you’re not measuring accurately, how can you manage effectively?
  14. Set Yourself Up for Success  Environmental = Chemical/Pollutant  For proper management you need to know: – What chemicals are used? – Where do those chemicals go?  This can seem like a complex problem… – 5,000 questions to answer – Where do you start?
  15. Let’s take a look at the typical game plan…
  16. Lots of Disconnected Spreadsheets. Not Good.
  17. The Alternative
  18. Material & Facility Modeling
  19. Material & Facility Modeling  Based on our 20 Years Experience  Boils the problem down to 2 questions 1. What materials am I using? 2. What goes on in my processes?
  20. 4 Pillars for a Successful System 1. Material & Facility Modeling 2. One database, multiple outputs 3. World class environmental record keeping 1. Accurate 2. Transparent 3. Keep data in “raw” format 4. List of applicable regulations
  21. Flagging Chemicals
  22. Material & Facility Modeling
  23. Your Materials  Track 3 critical data sets: 1. The chemical contents of materials • CAS • Relevant chemical properties 2. Amount purchased 3. Amount used
  24. What’s In Your Materials?  Few ways to determine: – Get data direct from suppliers – Batch determination – Scraped from SDSs (GHS – formerly MSDS)
  25. Material Data Management  Revision Tracking – Archive old records (5 years minimum) – Spreadsheets don’t archive
  26. Your Facility  Map out your facility processes  Look at each step in your manufacturing process – Materials used – Impacts to: • Air • Water • Waste – Recycling – Energy
  27. Your Processes  Look to understand – Source of emissions/waste – Effects of processes • Transfer efficiencies, emission factors, etc. – Mass balance – Pollution control devices • Stack tests
  28. The Big Picture
  29. What Your System Will Produce Complete on-site chemical inventory Amount of materials processed Air, water & waste profiles
  30. Processed Processed
  31. Potential Problems  Problems if you don’t do things right – Fines – ECHO list (Stock market – NYC) – More frequent Audits – Shutdown
  32. How to Avoid These Problems  Maintain comprehensive records  Respect your Auditors – They are not the enemy – Use them as a resource – Understand their situation – Provide what they need • If you don’t have it, provide it later
  33. Auditor’s Mindset  Their main goal: – Work with industry – Make them aware of requirements  Their favorite part of the job: – Working with industry – Maintaining a good working relationship – Enjoying the benefits for everyone involved
  34. Auditor’s Mindset  REMEMBER: Your Permit is a Contract – Essentially “Permission to emit”
  35. Auditor’s Mindset  Auditors WILL have done their homework before arriving  They will have reviewed: – Draft inspection template – Your permit – Your record keeping requirements – Your previous reports
  36. Auditor’s Mindset  They expect YOU to do YOUR homework – Review your permit – Review your records – Ask “Here is my emissions limit, how am I tracking that?”
  37. Biggest Problems an Auditor Faces  Poor record keeping  Company’s knowledge of – Facility – Permit(s)  Turnover in EH&S staff – Business continuity
  38. Biggest Problems an Auditor Faces  Having to teach & explain during inspections  Time! – Several inspections scheduled – Excessive time spent means missed inspections – Don’t be the person that holds them up because you’re disorganized!
  39. Advice from Auditors  Look into unpermitted equipment  Be centrally organized in a single location – Permits – Permitting requirements – Semi annual reports – Usage records – Any type of record keeping that’s required under their permit
  40. Advice from Auditors  Be aware of your industry changes  Compliance is going to become more complex – More federal regulations coming – More industries affected  Go and talk to them
  41. In Case You Have a “Record”
  42. How Your History Affects You  Bad reputation = prior violations.  Conducting more inspections on a more frequent basis.  BUT…. You are not treated differently
  43. How Your History Affects You  Auditor’s have a program to determine fine size  Based on: – Severity – Duration – Repeat violation? – Under your control? – Were you co-operative? – EPA determine “adequate enforcement”
  44. How to Clear Up Compliance Issues  Go to their office and talk to your auditor  Bring your permitting people or plant manager  They will go through your permit – Look at what violations have occurred – Find out why they’re happening – Help you fix it  They will be eager to work with you
  45. Get a New Permit  Your permit is not written in stone  In certain cases: – Consultant drafted the permit – Too complicated to follow – Makes compliance extremely difficult  Talk to auditor about making changes
  46. Build Business Continuity  To ensure continuity, auditor’s recommend: – Centralized system – Easy to understand – Keeps data in raw format
  47. Complete Internal Audits  Advantages of doing internal audits: – Get more efficient – Cut costs – Be proactive – Make your workplace safer
  48. Questions?

Editor's Notes

  1. STORY: Guy in Virginia was too busy doing engineering projects, submitted bogus data, ticked off the state, left and company left holding the bag. STORY: Roy validating a system to sign off on so he didn’t have to constantly check what he was signing. He could trust the outputs from the system.
  2. Looking at each part, you will be able to see the exact chemical composition, with each chemical flagged for different regulations in each region.
  3. This allows each supplier to not only deliver parts to Toyota’s manufacturing facilities, but it also allows them to pass the chemical composition data to Toyota’s Environmental Management System.
  4. STORY: JBP Co – California has strict record keeping. Main environmental guy decided to leave for a day or two, but family issues kept him away for 3-4 months. You’ve got a facility running, compliance keeps moving forward, you don’t have time to get someone new.
  5. STORY: Boat company in Texas was tracking chemicals incorrectly. They didn’t have the software, they didn’t do a good job of keeping track. Noticed that a tremendous amount of acetone was being used and it was never being used on boats, it was being used for meth labs.