Tighe&Bond - EHS Seminar - Middletown CT

Breakfast Seminar Series
Environmental, Health & Safety
Regulatory Updates
Introductions
October 25, 2016 Middletown CT
Wayne E. Bates, PhD, PE, Principal Engineer

Firm Overview
■ Multi-disciplinary Consulting Firm Founded in 1911
■ Full Service Capabilities: 280 Person Staff
■ Employee Owned
■ 8 Offices in MA, CT, NH and NY

Tighe & Bond Full Service Capabilities
Civil Engineering
•Dams & Levees
•Geotechnical
Engineering
•Infrastructure
•Land Use Planning
•Low Impact Design
•Parking & Circulation
•Site Planning &
Design
•Transportation
Environmental
Consulting
•Brownfields
•Demolition &
Asbestos/ Hazardous
Materials
•Environmental
Permitting & Planning
•Fuel Storage
•Health & Safety
•Regulatory
Compliance
•Site Assessment &
Remediation
•Wetlands and
Ecological Services
Building Services
•Geotechnical
Engineering
•Electrical &
Mechanical
Engineering
•LEED Green Design
•Owner’s Project
Manager
•Structural Engineering
Technology
•3D Modeling
•GIS
Sustainability
•Energy & Resource
Conservation
•LEED Green Design
•Low Impact Design
•Renewable Energy
Environmental
Engineering
•Drinking Water
•Solid Waste
•Stormwater
•Wastewater

About our Speakers?
■ Regulatory Experts
■ Actively engaged in professional societies
■ Track regulations
■ Good reputation among regulators
■ History of helping clients with regulatory
challenges
■ Ability to assist in determining applicability

EH&S Regulatory Updates
October 25, 2016 Middletown, CT
Timothy K. Kucab, CHMM, Project Compliance Specialist
Air Quality

■ Agenda
– What’s New?
– Planning for 2017
– Emergency Generators
– Noise and Siting
– Top 5

What’s New
■ 2015 GPLPE Issued on November 9, 2015
– Less than 50% of the Title V thresholds
– Up to but no more than 80% of the Title V thresholds
■ Fuel Sulfur Content – Stationary Sources

Don’t Forget….
■ Maximum Allowable Stack Concentration

Planning for 2017
■ Reporting Season
– Semi-Annual / Annual Compliance Reports (January)
– NESHAP/MACT Annual Updates (January, March)
– GPLPE Annual Compliance Certification (March)
– Risk Management Program (Varies)

So You Operate a Generator…
New
Old
Emergency
Non-
Emergency
Area Source
Major Source
of HAP
Installation
Date
Generator Use
Facility HAP
Emissions

Types of Requirements
■ Emergency
– Monitoring
– Recordkeeping
– Operating Limitations
– Fuel Requirements
– Emissions Limitations
■ Non-Emergency
– Controls
– Performance Tests
– Reporting
– Notifications

Emergency Engines Nuts and Bolts
■ Emergency engines may operate for 100 hr/yr for any combination of the
following:
■ maintenance/testing;
■ emergency demand response
■ 50 hr/yr of the 100 hr/yr allocation can be used for:
– non-emergency situations if no financial arrangement

Emission Dispersion
■ “Good Engineering Practices”
– No Shanty Caps or Egg Beaters
– Vertical exhaust
■ Stack Height – Requirements May Vary
– 10 Feet Above Nearest Roofline
– If the stack is lower than 1.5 times the building height or lower
than the height of a structure that is within 5L of the stack (5L
being five times the lesser of the height or maximum projected
width of the structure) – MODELING REQUIRED
■ Other states have additional requirements

State Requirements
■ Individual Permits
■ General Permits
■ Permit-by-Rule
■ Certifications

Siting Considerations
■ Impacts from Project
– Sound Levels
– Visual Impacts
Generator
Housing
Generator
Exhaust
Residence
less than
25 feet
away

Noise Considerations
■ Noise Policies
– Sound Levels
– Pure Tones
■ Zoning Specific Noise Provisions
■ Sound Level Monitoring
– Pre-Construction
– Post-Construction
– Ambient

Top Five Things Regulators Look For
■ #1 Recordkeeping
– Every Permit Condition
■ #2 Reporting
– Don’t Miss Deadlines
■ #3 Inspections
– Document Required Inspections
■ #4 Non-Delegated Regulations
– Local / State / Federal
■ #5 General Duty
– Facility Condition

Doug Stellato, Project Compliance Specialist
Timothy Kucab, CHMM, Project Compliance Specialist
Hazardous Materials

But first…
Wastewater Discharges

Wastewater General Permits
 Categorical Industrial User Wastewater to a POTW
 Domestic Sewage
 Food Service Establishment Wastewater
 Food Processing Wastewater
 Groundwater Remediation Wastewater Directly to Surface Water
 Groundwater Remediation Wastewater to Sanitary Sewer
 Hydrostatic Pressure Testing Wastewater
 Low Flow Water Treatment Wastewater
 Miscellaneous Discharges of Sewer Compatible Wastewaters
 Nitrogen Discharges
 Non-Contact Cooling and Heat Pump Water
 Photographic Processing Wastewater
 Printing and Publishing Wastewater

MISC General Permit
■ Wide Variety or Processes
■ Easy Approvals
■ Allows low volume discharges
without sampling
■ Expired – Continued
Authorization

Regulatory Updates – Hazardous Materials
■ Tier II Reporting
– 10,000 pounds
– Extremely Hazardous Substances
– Tier II Manager
■ Chemical Control Laws
– Alphabet Soup of Regulations
– Updated Frequently
■ TSCA
– June 2016 Update
– Evaluate existing chemicals
– Risk-based safety standard
– Improved public transparency

Planning for 2017– Hazardous Materials
■ Tier II – March 1, 2017
– Tier II Manager upload of facility
– Consultant Access
■ CA Prop 65
– Updated frequently
■ SVHCs
– Updated in June and December
■ Supply chain driven
– Products imported into Europe
– Conflict Minerals
■ Preparing or reviewing Safety Data Sheets
– Section 15 information

Planning for 2017– Hazardous Materials
■ TSCA
– New Inventory rule
» Proposed by December 2016
» New rule by mid-2017
» 10 years of reporting
– New chemicals approved prior to going to marketplace
– Mercury compounds export ban September 2016
– New review process will rely on chemical use

■ #1 Accurate Inventory
– Inaccurate amounts can lead to issues with other programs
■ #2 Site Diagram
– Shows location of each reportable chemical
■ #3 Up-to-date SDS
– Purchased and manufactured substances
■ #4 Testing Data
– For chemical concentrations
■ #5 Maintain Import & Export Records
– Is a broker being used?

Jeff Bibeau, REM – Principal Compliance Specialist
Hazardous Waste

Agenda – Regulatory Updates
■ Hazardous Waste Determinations
■ Hazardous Waste Management
■ 2017 Hazardous Waste Action Items
■ Top 5 Hazardous Waste Compliance Items

Hazardous Waste
■ EPA Listed Wastes (F, P, K and U)
■ Characteristic Hazardous Waste exhibits one or
more of the following characteristics:
– Ignitability (flashpoint <140 degrees F)
– Corrosivity (pH <2 and >12.5)
– Reactivity (normally unstable/emits toxic fumes)
– Toxicity
■ All businesses are required to perform a Hazardous
Waste Determination on the waste they generate
– CTDEEP requires to test annually or if process change or not changed
over time then ”knowledge of process”
– Maintain a copy of these determinations

Hazardous Waste:
The Nuts and Bolts
■ Labeling
– All drums of HW must be properly labeled:
» CENTRAL ACCUMULATION AREA
– Label must have accumulation start date
» SATELLITE ACCUMULATION AREA
– Label should NOT be dated until drum is full
– Only 1 drum per waste stream can be located in an area
■ Management
– Keep drums closed at all times. Avoid the following:
» An open funnel is an open drum = penalty
» An unlocked ring around a solids drum is an open drum = penalty
■ Disposal
– Cradle to Grave
» Responsibility of proper disposal and recordkeeping is always on the GENERATOR, not the
hauler
■ Universal Waste
– Bulbs, Batteries, Ballasts, Thermostats, etc.
» Must be in a closed, labeled and dated container
» Can accumulate for up to 1-Year

Hazardous Waste:
The Nuts and Bolts
■ Generator Status
-Conditionally Exempt Small Generator (CESQG):
» generate <220 pounds/month
» accumulate <2,200 pounds
-Small Quantity Generator (SQG):
» generate 220-2,200 pounds/month
» accumulate <2,200 pounds/month
» <180 day on-site accumulation
» weekly Inspections
-Large Quantity Generator (LQG):
» generate >2,200 pounds/month
» accumulate >2,200 pounds/month
» <90 day on-site accumulation
» Biannual Report/Contingency Plan/Annual Training/Weekly
Inspections

Hazardous Waste:
The Nuts and Bolts
■ Good Condition
■ Compatible with waste
■ Closed unless filling or dispensing
■ Clear markings
– Content
– Hazard Associated with the waste
– Start Date Accumulation

Hazardous Waste
■ LQG’s that store Hazardous Waste in Tanks:
1. <50 feet of the property line
2. Must be designed in accordance with special
design requirements (PE stamp)
3. Tightness tested
4. Secondary containment/leak detection
5. When permanently cease using a tank perform
special cleanup activities
6. Tanks inspected by a PE and certify as to their
integrity
7. Daily inspections
 Must comply with EPA air emission standards
for Tanks (40 CFR Subparts AA, BB and CC)

Planning for 2017
• Hazardous Waste Management = 100% compliance 100% of the time
• Weekly Inspections
• On-site accumulation limits (LQG=90 days; CESQG=180 days)

■ #1 Container Management
– Label information, closed containers
■ #2 Generator Status
– Monthly Generation limits and on-site accumulation time limits
■ #3 Reports/Contingency Plan
– Biannual HW reports/Contingency Plan updats
■ #4 Inspections
– Documented inspections (time/date/full name)
■ #5 Central Accumulation Area
– Line of demarcation, signage, emergency call list, fire
extinguisher

David P. Horowitz, PE, CSP, Project Manager
Tanks

■ Tanks
– Federal Perspective
– CT DEEP Nuts & Bolts

Regulatory Updates – Tanks (Above ground)
■ Bad Tank News
– Port Arthur, TX
» Explosion, fatality,
injuries
– Elk River - West Virginia
» Chemical leak, 300,000
w/o water
– Smith County, TX

Regulatory Updates – Tanks (Above ground)

Regulatory Updates – Tanks (underground)

FAQs – Tanks
■ Is there a deadline for designating UST Class A,
Class B, and Class C Operators and submitting
Class A and Class B Operator names and training
details to DEEP?
– Yes, effective August 8, 2012
■ If an UST Owner/Operator has more than one
location, must the Class A and Class B Operator
information be submitted for each facility?
– Yes, use DEEP ezFile

FAQs – Tanks
■ Can Class A and Class B Operator information be
submitted electronically through ezFile?
– Yes, use
■ Can the same person be designated both the Class
A and Class B Operator?
– Yes, provided the designated person has passed both a Class A
and Class B Operator exam.
■ Are all employees of a facility required to be Class
C Operators?
– No, each facility must have at least one Class C Operator.

FAQs – Tanks
■ Can a facility owner contract with a third-party to
be a designated Class A and/or Class B Operator?
– Yes
■ Can a facility owner contract with a third-party to
be a designated Class A and/or Class B Operator?
– Yes
■ What is necessary to have a training course
approved for Class A, Class B, and/or Class C
Operator Certification?
– Complete the applicable Class A, B, or C Operator Training
Course Criteria

Typical Deficiencies – USTs Inspected (No
Retail)
Deficiency % Identified
Maintenance 91%
Financial Assurance 84%
Sump Monitoring 66%
Registration 61%
Overfill Prevention 38%
Cathodic Protection 18%
Double Wall Piping Issues 12%
Shear Valve 11%
‘Extra’ Vents 6%

Top Things Regulators Look For
1. Managing sumps & spill
buckets (USTs)
2. A/B/C Operator coverage
(USTs)
3. Financial Assurance (USTs)

October 25 Middletown, Connecticut
Kevin McCarthy, Project Manager
Hazardous Building Materials

■ Tanks
■ Hazardous Materials
■ Toxics Use Reduction (TUR)
■ Air Quality
■ Water/Wastewater
■ Hazardous Building Materials (HBM)
■ Safety and Health
■ Auditing

Asbestos
Containing
Materials
Mercury
Containing
Devices
Lead
Based
Paint PCB/DEPH
Containing
Light
Ballast
PCB
Containing
Building
Materials

– Regulatory Compliance Required for Public and
Private Sectors
– Two Areas of Compliance
» Operations and Management (O&M) of Existing In-
Place Materials
» Management (Abatement) during
Renovation/Demolition
– Regulators
» EPA (Enforced by CTDEEP)
» CTDPH
» OSHA

Asbestos Containing Materials
– Renovation and Demolition
» EPA NESHAP Regulations
» EPA ASHARA Regulations
» CTDPH Standards for Asbestos Abatement
» CTDPH Licensing and Training Requirements for
Persons Engaged in Asbestos Abatement and
Consultation Services
» OSHA Asbestos in Construction
– Operations and Maintenance
» OSHA Asbestos in General Industry

Asbestos Containing Materials
■ Is your Building Subject to an Inspection Prior to
Renovation or Demolition?
– Yes - Any structure (regardless of building age) requires a
survey
– Used to confirm or deny the presence of asbestos containing
materials
– All building materials are suspected asbestos containing
materials (Exemption – wood, glass, fiberglass, metal, and
plastic)
■ Is your Building Subject to an Operations and
Management Plan?
– Maybe – Any structure constructed prior to 1980

Lead Based Paint
– Mainly regulated in child-occupied building or target
housing by EPA RRP Rule, HUD Lead-Safe Housing
Rule, and CTDPH Lead Poisoning Prevention and
Control regulations
– EPA RCRA regulations
» Disposal limit for hazardous lead waste vs.
general construction and demolition waste
– OSHA Lead in Construction
» Worker Protection
» Hazard Communication

PCB/DEPH Containing Light Ballasts and
Mercury Containing Devices
– PCB/DEPH Containing Light Ballasts
» PCB ballasts banned in 1979
» DEPH ballasts banned in 1991
» Requires appropriate disposal
– Mercury Containing Devices
» Universal Waste
» Requires appropriate disposal and/or recycling

PCB Containing Building Materials
■ Regulated by EPA and CTDEEP
– EPA regulates source materials at ≥50 ppm and adjacent materials
contaminated by source materials at >1 ppm
– CTDEEP regulates ALL materials at > 1 ppm
■ Never authorized by EPA or CTDEEP for use
– Highly unlikely to be authorized
– Only continued use of PCBs is within closed containers
(transformers)
■ Testing
– Test if there is a planned renovation or demolition project which will
disturb suspect PCBs containing building materials and result in
disposal of suspect materials
– Air testing to determine if a potential problem exists

October 11 Holyoke Mass
October 25 Middletown CT
Alan Stratton, CSP - Project Manager
John S. Gannon, Esq. - Attorney with Skoler, Abbott & Presser, P.C.
Safety & Health

Defending OSHA Citations
How to handle inspections,
negotiate penalties and
defend citations
Defending OSHA Citations
How to handle inspections, negotiate
penalties and defend citations
John S. Gannon, Esq.
Attorney with Skoler, Abbott & Presser, P.C.
jgannon@skoler-abbott.com
www.skoler-abbott.com

OSH Act
■ Duties clause: Each employer --
– (1) shall furnish to each of his employees employment and a
place of employment which are free from recognized hazards
that are causing or are likely to cause death or serious physical
harm to his employees (Sec. 5(a)(1));
– (2) shall comply with occupational safety and health standards
promulgated under this Act (Sec. 5(a)(2))

OSH Act
■ Violation of standards: 5(a)(2) violation
■ Common violations:
– 1926.501 – Fall Protection
– 1910.1200 – Hazard Communication
– 1910.134 – Respiratory Protection
– 1910.147 – Lockout/Tagout
– 1910.212 – Machine Guarding
– 1926.652 – Excavations

OSH Act
■ General duty clause: 5(a)(1)
– Ex:
» Exposure to crushing hazard
» Lack of emergency stop devices
» Lack of workplace violence policy
» Repeated lifting above shoulder height
» Standing for long periods without adequate support

OSHA Complaint Handling
■ OSHA can conduct on-site inspection or refer for
phone/fax investigation
– Phone/fax: OSHA calls employer, follows up with fax detailing
alleged safety hazards
– Employer responds in writing, if adequate OSHA will close case
with no inspection
– Used for lower-priority hazards

OSHA Complaint Handling
■ On-site inspections typically reserved for:
– Complaint by employee with enough detail to enable
OSHA to determine that a violation or danger likely
exists that threatens physical harm
– Inadequate response from an employer who has
received information on the hazard through a
phone/fax investigation
– Complaint against an employer with a past history of
OSHA citations
– Targeted inspections against specific high-hazard
industries

On-Site Inspections
■ Begins with “knock at the door”
– No appointments necessary!
■ OSHA official will display credentials, inform
employer why there, ask to enter
■ Request a warrant?
– Employer has right unless hazard in plain view or employer gives
consent
– Expect more scrutiny if requesting a warrant

On-Site Inspections
■ Starts with opening conference
– Explain why facility selected
– Purpose of visit, scope of inspection, applicable standards
– Complaint copies may be distributed (ask for copies)
■ Employer should:
– Negotiate to narrow the scope of the inspection
» Limited to the complaint
» Protect trade secrets
– Designate employer representative
» Should be trained on the process
– Try to establish ground rules with OSHA about how inspection
may proceed
» collection of documents (through written requests only)
» interviews (scheduled in advance)

On-Site Inspections
■ Inspector conducts “walk-around,” looking for
hazards
– May review OSHA 300/300A logs
– May ask for other safety-related documents, ask to talk to
witnesses
– This is why narrowing scope is crucial!
■ Closing conference: Inspector discussed findings
and suggested courses of action
– Citation may be issued later

Citations
■ Citation will propose penalty, cite to
standard/regulation, require abatement and
posting
■ Penalty amount will be based on:
– Violation type
» Serious/repeat/willful
– Employer size
» Up to 70% for small business (1-10 employees), no reduction
for 250 + employees
– Citation history
» 10% reduction if inspected w/in last 5 years with no violation
» 10% increase if employer has citation history
» History available here:
https://www.osha.gov/pls/imis/establishment.html
– Good faith reduction
» Up to 25% if employer has written safety program

Informal Conference
■ Meet with Area Director and suggest adjustments
■ Must be requested immediately!
■ Employer only has 15 days to to contest citation,
informal will not extend timeframe
■ What to expect at conference
– AD will let you present your case
– Be prepared to make proposal, present safety documents
» Propose less money/reduction of penalty type
» OSHA looks for consistent enforcement of safety policy
» Unlikely to get exculpatory language

Possible Defenses
■ Wrong safety standard cited
■ No general duty violation
■ Evidence does not support alleged violation
■ Multi-employer citation
■ UEM: Unpreventable Employee Misconduct
1. Established work rules;
2. Work rules communicated to employees;
3. Employer takes steps to discover violations;
4. Rules enforced when violations discovered
5. Not available if supervisor engages in misconduct
■ Harassment? Unlikely!

Contest Citation
■ Must file Notice of Intent to Contest (in writing)
w/in 15 days of citation date
– Must be specific as to what is being contested
■ OSHA Area Office forwards to DOL Solicitor's
Office, formal Complaint issues
■ Answer, discovery, trial-style hearing, appeal to
OSHA Review Commission, then federal court
– Should have more chances to settle
– Might get exculpatory language
– Negotiate payment plan

Should We Contest?
■ Factors to consider:
1. Cost/time to abate the alleged hazard
» What must be done to fix? Change in equipment? Impact
on rate of production?
2. Potential for repeat citation
» Second citation substantially similar?
» Repeat policy applies to all locations
3. Characterization as willful
» Intentional violation of the law
» Future inspections likely
» Issues in collective bargaining? Insurance premiums?
4. Impact on ability to compete for new projects
5. Collateral litigation

Whistleblower Retaliation
■ Employees cannot be punished for complaining
about unsafe working conditions
■ Lengthy investigative process, OSHA has right to
request employee records and interview employee
witnesses
■ Significant potential liability, including:
– Reinstatement with back pay
– Front pay if no reinstatement
– Emotional distress damages
– Attorney’s fees

October 25 Middletown, CT
Alan Stratton, CSP - Project Manager
Safety & Health

Regulatory Updates – Safety & Health
■ Respirable Crystalline Silica
■ Federal Civil Penalties Inflation Adjustment
Act Improvements Act of 2015
■ Recording and Reporting of Occupational
Injuries and Illnesses regulations

■ Respirable Crystalline Silica
– Issue Date: March 25, 2016 / Effective Date: June 23, 2016
– Compliance Dates:
» Construction: June 23, 2017 / General Industry: June 23, 2018
– Highlights:
» New P.E.L. of 50 µg/m3 / 8 hour shift
(1/2 Prior Limit in General Industry / 5 times lower in Construction)
» New Action Level of 25 µg/m3 / 8 hour shift
» Requires initial, in some cases follow-up, exposure monitoring
» Requires engineering controls and work practices
» Requires development of an Exposure Control Plan
» Must consider designated list of controls

■ Federal Civil Penalties Inflation Adjustment Act
Improvements Act of 2015
■ Translation: Higher OSHA Fines
– Highlights:
» Serious $7,000 → $12,741 per violation
Other Than Serious $7,000 → $12,741 per violation
» Failure to Abate $7,000 → $12,741 per day
» Willful or repeat $70,000 → $124,709 per violation
» Effective August 1, 2016
» First increase in over 25 years
» Allows future increases by January 15 every year

■ Recording and Reporting of Occupational Injuries
and Illnesses regulations
– Highlights:
» Large Businesses (≥ 250 employees)
– Electronically file OSHA 300 / 300A / 301 forms with OSHA
– Begins July 1, 2017 (300A form), All forms in 2018
» Small (High Risk) Industries (20 – 249 employees)
– By SIC Code (e.g., utilities, construction, manufacturing)
– Electronically file OSHA 300A forms with OSHA
– Begins July 1, 2017
» Injury / Illness data will be available to the public
» Employers can not retaliate for injury reporting
– Automatic drug testing can be a form of retaliation
» Electronic reporting is being challenged and may be modified

Planning for 2017– Safety & Health
■ Annual Safety & Health Requirements
– Post OSHA 300A Log: Post from Feb 1 → through April 30
– Initial Training:
» LoTo, Emergency Action Plan, HazCom, PPE, Hearing Protection…
– Refresher Training:
» Annual: Hearing Protection, Respirators, Access to Medical Records…
» 3-Year: Powered Industrial Trucks
– Mandatory Program Reviews:
» Exposure Control Plan (BB Pathogens), Confined Space, LoTo….
– Annual Evaluations:
» Audiograms, Respirator Fit Tests
– Process Changes:
» Training, Program Updates, Hazard Reviews, PPE Assessments…

1. The common / obvious violations
» OSHA Top 10 List
» Visible - Low hanging fruit (Extension cords, No Written Programs, No Training...)
Preliminary 2016
Top 10 List

2. Federal OSHA Exempt Facilities?
State and Municipal Employees?
» Subject to: Connecticut Department of Labor's
Division of Occupational Safety and Health (CONN-OSHA)
3. Federal / Local Emphasis Programs
» Fall Protection
» Fork Trucks
» Amputations
» Process Safety...
4. Employee Complaints & Injuries
5. High Risk & High Injury Rate Facilities / Operations

October 25 Middletown, CT
Compliance Tools – Chemical
Inventories & Compliance Calendars

Compliance Tools
■ Chemical Inventories
■ Recordkeeping Databases
■ Compliance Calendars

Chemical Inventories
■ Track materials stored &
quantity used
■ Used for multiple programs
– Tier II
– Greenhouse Gas Reports
– Source Registration
– TURA reporting
– TRI reporting
– Chemical Control Laws

■ Challenges
– Multiple spreadsheets or lists
– Multiple people responsible
– Missing data
– How to verify data
■ Accuracy is essential
– Over-reporting
– Under-reporting
– Amended reports

Materials
ordered
Manufacturing
Products
Manufactured
CAS #
CAS #
CAS #
Product Flow
CAS #
CAS #
CAS #
Information Needs
Receiving
Dock
Shipping
Dock
CAS = Chemical Abstract System

Chemical Use
Materials
Emissions
ProductsWaste
Used
inventory

Recordkeeping
■ Track materials used and emissions
■ Used for multiple programs
– Air Permit Reporting
– Air Permit Recordkeeping
– TURA/TRI applicability
■ Track all conditions of permit!
– VOC/HAP concentration limits
– VOC/HAP emissions
– Annual reports

Chemical Use and Recordkeeping
Chemical
Information
Process
Information
Chemical
Use
Properties
Parameters
Regulatory
Requirements
Thresholds
Product
By-Product
Waste
Emission
Inventory Recordkeeping Reporting

Calendars
■ Track “typical” and non-“typical” reporting
deadlines
■ Track inspections or sampling
– Hazardous waste
– SPCC & SWPPP
– Wastewater sampling
■ Track Employee Training
– Hazardous waste
– DOT
– SPCC & SWPPP
– Wastewater licenses

■ Chemical inventory
– key for material use, storage, and emission calculations
– Establish systems at receiving dock
– Use information for multiple regulatory programs
– Regularly check and test data accuracy (3rd party)
■ Recordkeeping
– Use data to generate compliance reports
– Ability to export data for other uses and metrics tracking
– Stay up to date on regulatory changes
■ Compliance Calendars
– Use alerts and reminders
– List applicable programs and frequency
– List non-applicable programs with thresholds
– Integrate inventory, recordkeeping and calendar
Conclusion

Auditing

Common Risks
■ Regulatory
– Audit or inspection
– Maintaining compliance
– Adapting to changing regulatory environment
■ Corporate
– Compliance with regulatory programs
– Conformance with company policies and procedures
– Due diligence
■ Supply Chain
– Requirements for doing business
– Limiting exposure
■ Certifications

Common Findings
■ Safety & Health
■ Environmental

Safety and Health
■ Industrial Facilities
– 7 of 10 are general industry
– 3 of 10 are construction

Environmental
■ Industrial Facilities
– Risk Management Planning
» Process Safety Information (PSI)
» Signage
» Management of Change (MOC) issues
» Employee Training
– SPCC Plans
» Site plan
» Discharge location
– Hazardous waste
» Labelling
» Storage
» containers

Planning for Compliance
Applicability
Conformance
Compliance

Planning for Compliance
■ Regulatory Applicability Review (annual)
– Create or update the compliance matrix
– Establishes or updates the compliance calendar
■ Regulatory Conformance Review (1-2 years)
– Verify conformance with regulatory requirements
– Verify that calendar events are completed
■ Regulatory Compliance Audit (3-5 years)
– In-depth review of programs
– Review of operations and inventories
– Review calculations and permit conditions
– Challenge compliance

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