As a facility/plant manager, you know that documentation is required for certain permits and by many regulations covering your facility.
For example, the Resource Conservation and Recovery Act (RCRA) requires you to account for all the hazardous waste at your facility from generation to post-disposal – that’s why RCRA is known as the “cradle to grave” regulation. Many facilities simply have a difficult time complying with RCRA and we’ll go into details on why in just a moment.Completing certain documents required by law, to avoid facing penalties, shouldn’t be the only reason you practice good documentation. Besides compliance, documentation also helps with:
If you are thinking that you could do a better job with documentation, you are not alone. As an environmental consultant, we visit many different types of facilities and have seen many cases where documentation was incomplete, done incorrectly, or not done at all when required… sometimes with the company and facility being completely ignorant that they were doing anything wrong. Did you know that the lack of proper documentation is often the leading cause of environmental, health and safety compliance violations and fines?
This is why documentation is considered one of the Four Core Requirements of managing the environmental, health and safety issues at a facility; the others being property history, communication, and facility knowledge.
All these factors work in conjunction to help you run a safe, environmentally friendly, and profitable facility.
Without a good documentation program at your facility, things will go awry.
Let’s get back to the hazardous waste.
As the generator, you are responsible for identifying all the solid waste at your facility – even common trash. Then, you must conduct an evaluation to determine if that solid waste is hazardous or not, and you must “demonstrate proof” that you conducted that evaluation if you are ever inspected by a regulator. The easiest way to “demonstrate proof” is through documentation.
Many generators do not conduct this waste evaluation, and as a result, the lack of documentation relative to this issue is one of the most frequent compliance violations that is identified during RCRA regulatory inspections.
So how do you conduct this RCRA-required evaluation?
You can start with a Safety Data Sheet (SDS) to help determine if a waste may be hazardous. SDSs contain helpful information on chemical properties, health hazards, protective measures and safety precautions. But while many think that SDSs are enough, they are just a starting point. You see, SDSs list constituents in percentages and only typically show hazardous constituents that make up at least 1% of the material covered by the SDS.
The problem here, is that when determining if something is hazardous, you have to look at concentrations in parts per million of a contaminant or constituent in a material. Remember, one percent of something is the equivalent of 10,000 parts per million. In other words, a contaminant or constituent could make up way less than 1% of a material (and not be listed in a SDS), but that contaminant or constituent can cause the material to be hazardous because there are several thousand parts per million present in the material.
You can also use the generator’s knowledge of the waste material to help with this evaluation.
However, the best practice in this situation is to take a sample of the waste and send it to the lab. Tell them you need the material analyzed for RCRA hazardous constituents. The lab then sends back a report with all the concentrations listed and whether it’s hazardous or not. The bonus here is that you can use that lab report as your demonstration of proof that the waste evaluation was performed!
When, as consultants, we go into a facility and see a facility/plant manager or environmental manager who makes documentation a priority, it really gives the impression they know what they’re doing.
It certainly makes our job easier, and, as a result, our services are less expensive for our clients, as we generally spend less time on site. And, good documentation is really not that hard to do.
One thing we stress is to get in the habit of documenting everything at your facility as far as how, why, and where you did things. Remember, our memories are not as good as we think they are. This part of documentation could be a simple journal entry of just a few words detailing what occurred. This also helps to avoid repeating a past mistake.
You should also go through your records and note what documents are:
Once you go through that exercise, create a central repository to store these historical documents so you have control over them. We recommend a filing cabinet in your office.
Anything your predecessors generated – historical information, notes, files, figures, drawings, pictures, whatever – should go in there, too, to build your knowledge of property history.
One key thing to note: make sure anything that goes into that filing cabinet is a complete copy.
Say you had an underground storage tank removed at your facility. Tank removal reports tend to be several hundred pages, mostly due to the laboratory reports that are generated from the sampling conducted as part of the tank closure process. Some folks just keep the executive summary of these reports. But in reality, you need the whole thing because there is valuable information sprinkled throughout that report, especially for future assessment purposes.
For example, that tank, which was close to a building, is removed. And now the company wants to expand its building footprint over where the tank was once located. That may require soil sampling and/or borings by a geotechnical firm to determine soil conditions in the area.
But the company may have already collected sufficient information relative to soil conditions as part of the process of removing the tank. And if they’ve saved the records and results – no need to do it again, thus saving time and money.
One documentation issue we often see crop up with clients is when we review their environmental, health and safety policies and programs.
Take contact hierarchies in Spill Response Plans, for example. Basically, in the event of a release, it shows the employee what to do and whom to notify. But often, the contact hierarchy in these plans is outdated.
The people listed as important contacts no longer work there or their contact information is incorrect. The hierarchy is basically useless at that point – and out of compliance, which results in the plan being useless.
Another problem is training. It’s one of the best investments you can make at your facility to have well-trained employees – you always get a positive return on your investment. Besides, you may be required by regulations to train employees in specific activities and job functions, as well as environmental, health and safety issues.
But you could be rendering that training null and void if you don’t take one necessary step: you have to properly document that training. The regulator won’t take your word for it.
The documentation includes who was trained, what they were trained in, who did the training, and whether or not the training was completed. This goes for initial training, as well as refresher training down the road.
To make sure all your documentation is up to date, we recommend a spreadsheet be developed with a clock reminder for when training is needed for a certain employee or when key documents like contact hierarchies should be reviewed.
A big issue we come across, is that in today’s green age, people want to reduce paper usage. It’s admirable, and I support it, but there are some best practices to follow.
We go into facilities that have a wealth of historical documentation in paper format. And besides reducing the amount of paper they use, they want to reduce the amount of space needed for storage.
A seemingly easy way to do that is to scan the document into electronic files. That’s where some facilities run into problems.
After scanning, the document is illegible or the image isn’t clear or has disappeared altogether. Or just a portion of a file is scanned. Worthless. Often companies have an intern do that job, and they just don’t know any better.
One client gave us a burned CD to help us establish property history. But instead of maps of the site, all we got was the title block from each of the historical maps.
To avoid these outcomes, make sure you have a Quality Assurance policy in place. No paper copies get thrown out until that scanned image is confirmed to be correct and complete.
If you have a third-party provider do the scanning, make sure they don’t put everything into a proprietary file format that requires their software to open.
One company we worked with hired a vendor who later went out of business. They had to spend a bunch of money on file conversion to get access to their documentation.
To avoid all that, go with the universal file format: PDF.
If you’ve been falling behind on your documentation, now is the time to get your program into gear. It should be a part of your regular routine to safeguard important documents and records. And don’t forget a regular review to make sure everything is up to date.
When you have solid documentation, your facility runs more smoothly. It’s even better when you follow best practices for facility knowledge, communication, and property history.
Be sure to download this free information sheet and checklist on these Four Core Requirements to help you prioritize these important tasks in your day-to-day routine. It’s a great reminder to have on your desk.
