If you deal with hazardous materials at your facility, you know they require a whole additional layer of regulation-required permitting and reporting.
For example, a report detailing the hazardous materials that you store, use and/or release in the processes at your facility must be submitted every year by March 1.
This reporting requirement was established under the Emergency Planning and Community Right-to-Know Act (EPCRA) to ensure that the public had thorough knowledge of hazardous chemicals in facilities located in their communities.
The idea is that, armed with such information, these communities can improve safety and protect residents and the environment. As part of this, local committees, made up of local government and public safety officials, as well as representatives from the facilities and from community groups, must prepare emergency response plans.
Another example is the Form R report due on July 1. This Toxic Chemical Release Inventory report, which is also required by EPCRA, documents just what it says in the name: toxic chemicals released by a facility. But the facility must also show how the applicable chemicals are being managed through recycling, recovery, or treatment.
Companies know about these requirements. And they’re a big deal. But still, when we reach out to clients in January and offer to help them out with these reports, they often tell us they will handle it internally. I encourage them to get started sooner rather than later because that deadline has a way of sneaking up on you.
But then…
Invariably, I start getting calls about a week before March 1 from clients asking for help completing their Community Right-to-Know report.
We get it done, of course, but for a premium fee. If it’s along-time client I can be frank with, I emphasize that the report is relatively easy to put together. It just takes time. And it’s a matter of putting it on your calendar, making it a priority, and getting it done.
In other words, make a plan and stick to it.
This really brings home the importance of planning in every aspect of your facility when it comes to environmental compliance. There are many local, state, and federal regulations to keep track of, with related permits, reports, and other requirements. You cannot hope to keep it all organized and on track without planning, especially when you are so busy with the day-to-day management of your facility.
Not to mention, it’s so important for a company to have a positive ESG (environmental, social, and governance) score in today’s economy. More and more, your value as a company is tied into ESG, and you are being highly scrutinized in this regard.
That’s why it is so important to stay in compliance with environmental regulations. And making sure all required reporting is done in a thorough and timely manner is absolutely critical.
As I say, that means staying organized and having a plan. And that’s not just planning for an individual report or permit. You should have a comprehensive plan that covers all such tasks at your facility.
Planning Your Plan
Your first step in putting together a plan that ensures you stay in compliance is to carefully track everything going on at your facility in terms of your processes and what regulations and permits apply.
Make sure to thoroughly read and understand your permits, including the reporting requirements.
Determine what tasks must be accomplished to stay in compliance, including what data must be collected and how, as well as the deadline to submit a report and who it is being submitted to.
Much of this planning is relatively easy because, as in the case of the Community Right-to-Know report, the requirements are well established, and the information is due the same time every year.
Once you have those deadlines and what is needed, you can plan your year with that information in mind. Set time aside, in your actual work calendar, to get the reporting done well before it is due. That way you don’t have a deadline looming over you.
Items like this that you know are required to be submitted every year on the same date are the low hanging fruit, so to speak. Easy to do. But you should also take a fresh look at your facility to determine what other permits might be needed or other regulations that must be followed.
Even if you don’t currently have a permit covering some aspect of your operation, this can change over time due to a change in your process or materials used, for example. So, part of your plan is to take afresh look at your facility at regular intervals to make sure you are up to date.
At the same time, be sure to identify and catalog any potential risks at your facility, whether or not there is an associated permit. This could be in how you use materials, how you store materials… really any aspect of your operation.
Going through this process will help you reduce your overall environmental exposures and liabilities by helping you recognize overlooked issues – I call them invisible environmental gorillas – issues you have not paid enough attention to in the past.
Hunting for these invisible gorillas at your facility will become part of your yearly plan. Schedule time to address these issues. Set goals… and then achieve them on a regular basis.
You should also examine how your employees do their jobs and the training they have received. Make sure they are following proper procedures and have a full awareness of the importance of environmental, health and safety issues. That protects them but also the facility and the business as a whole.
As part of this, you want to include time for training, which could be required at certain intervals, in your yearly plan you are putting together. Like reporting, you don’t want to scramble at the last minute to complete required training.
So why not get started on your planning now? Once you have a plan in place and your year mapped out, you just carry it over year to year, modifying the schedule if necessary.
Being organized in this manner means staying in compliance becomes simpler and more straightforward.
Importantly, you are also better able to manage emergencies and unexpected issues if they pop up, such as accidental releases or an employee accident.
You can create your own plan or bring in a consultant familiar with your industry and/or specific operations to help you build out this framework.
At Envision Environmental, Inc., we are happy to help you put together your compliance plan. You can contact me, Mark Roman, at 609-208-1885 or get in touch via e-mail at markroman@envisionenvironmental.com.
