Multi-Media Environmental Audits
EHSS has conducted over eighty multi-media environmental audits for a leading transportation company. Audited facilities range in size from small scale operations to large operations spanning hundreds of acres. Each facility has its own unique set of environmental issues and concerns. EHSS conducts an extensive environmental audit of a facility in conjunction with detailed and comprehensive audit protocols. The audits are conducted based on applicable environmental regulations including, but not limited to, Clean Air Act, Clean Water Act, Safe Drinking Water Act, Solid Waste Disposal Act, Resource Conservation and Recovery Act, Toxic Substances Control Act, Comprehensive Environmental Response, Compensation and Liability Act, Emergency Planning and Community Right-to-Know Act, Hazardous Materials Transportation Act and the Federal Insecticide, Fungicide and Rodenticide Act. In addition, EHSS researches state and local regulations, statutes and ordinances which are applicable to the facility as well as any client specific environmental policies to verify the facility is adhering to all required regulations.
At the onset of the audit, EHSS meets with facility representatives to explain the audit process and to gain an overall understanding of basic facility operations. EHSS reviews all aspects of a facility including, but not limited to, areas of industrial activity, facility processes, material handling and storage areas, waste disposal handling and disposal areas, undeveloped outlying areas and facility environmental documentation. During the onsite inspection, information gained during the site overview is compared with site operations and conditions observed. Interviews are conducted with selected facility personnel to determine facility employee comprehension of environmental requirements and to verify the adequate implementation of environmental management systems and adherence to company environmental policies.
EHSS reviews facility environmental documentation including, but not limited to, environmental programs, plans, permits and reports to identify instances of noncompliance with environmental regulations. EHSS reviews records for a period of time equivalent to the retention period required by applicable regulations (typically three years). The scope of the documentation review includes the following environmental compliance issues and associated regulations and facility documentation:
- Federal, State and Local environmental permit requirements, including permit application, required reporting and recordkeeping;
- Determination that the facility is operating in compliance with respect to environmental permits issued to the facility;
- Review of environmental plans such as Spill Prevention, Control and Countermeasures Plan, Storm Water Management Plan and Facility Response Plan. Also includes review of all documentation as required by the individual plans;
- Documentation regarding the appropriate management, handling, storage and disposal of waste streams generated by the facility including waste determination documents, laboratory analysis reports and waste manifests;
- Verification of compliance with any federal, state or local notices of noncompliance or consent orders;
- Review of Emergency Planning and Community Right-to-Know submissions, Hazardous Chemical Inventory Reporting and Toxic Release Inventory Reporting (if applicable) to determine if submissions are accurate and submitted according to regulatory guidelines;
- Determination if the facility is operating in compliance with an implemented Environmental Management System (if applicable); and
- Review of other miscellaneous facility environmental records such as monitoring reports, storage tank registrations and other required regulatory reporting.
A report is prepared for the client upon completion of the audit identifying each instance of environmental noncompliance. Included with each finding is a corresponding regulatory citation, a summary of the finding and location of the finding. Photographs (if taken) are also included in the report to assist the facility in identification of the noncompliance issues. A recommended corrective action is also provided for each issue of noncompliance to provide the client with an appropriate response to the finding which is compliant with the regulatory citation.
Waste Management Program
EHSS personnel developed a system of waste disposal compliance verification for a Fortune 500 company. The system was designed to track every waste shipment generated by the company from over 200 facilities within the United States. Environmental personnel at each facility submit waste disposal documentation including draft manifests, waste profiles, disposal facility approval and waste characterization documentation (e.g. Safety Data Sheets, laboratory analysis, etc.) to EHSS for review. EHSS personnel review all documentation for completeness and to verify appropriate waste characterization and disposition. Disposals include hazardous, non-hazardous and universal waste. Review of disposal documentation requires extensive knowledge of both Federal and State waste disposal requirements to ensure compliance and reduce or eliminate the potential for future liability regarding improper disposal of waste material. Each shipment is assigned a tracking number and is tracked from generation to final disposition. When final documentation is received, the documents are uploaded to the client’s secure server for document storage and retrieval. In the last three years alone, EHSS personnel have processed over 50,000 waste shipments.
Hazardous Waste Management Compliance Program
EHSS provides our clients with a comprehensive waste management compliance program. The program addresses all aspects of hazardous and non-hazardous waste management including determination of appropriate waste characterization, preparation of waste profiles, waste disposal assistance and manifesting. EHSS utilizes a comprehensive waste tracking program to manage waste from generation through to final disposition. EHSS also provides tasks associated with waste management including, but not limited to, hazardous waste tracking, hazardous waste generator notification filing (EPA Form 8700-12), Annual/Biennial Hazardous Waste Reporting, Waste Minimization Plans, Hazardous Waste Contingency Plans and Waste Reduction Plans.
Sustainability Assurance Reviews
EHSS has conducted Sustainability Assurance Reviews for a Fortune 500 company to verify the company is operating and continues to operate in an environmentally sustainable manner. EHSS reviewed facilities to determine overall environmental sustainability and continuous improvement. Focus included, but was not limited to, storm water management, spill prevention control and countermeasure issues, solid waste management, hazardous waste management and universal waste management. The Sustainability Assurance Reviews were designed to assess the facility’s overall level of environmental compliance as well as to evaluate the effectiveness of the company’s environmental management system.”
The Sustainability Assurance Reviews also included interviews of high level employees to identify how environmental compliance is achieved and sustained at the facility. During the interviews, the employees were asked to evaluate the effectiveness of the environmental compliance and sustainability initiatives implemented by the parent company.
A formal report for each review was prepared and delivered to the client within 10 business days of completion of the review. The report identified each item of noncompliance as well as areas which would be better served through implementation of identified best management practices. Each facility was assigned a score based on a set of predetermined criteria developed by EHSS. The score identified where the facility stood on a scale of 1 to 10 (one being unsustainable and ten being highly sustainable). The report also included the results of the employee interviews and suggestions of how to improve environmental performance and sustainability.
Development of Environmental Awareness Training
EHSS has designed and developed numerous environmental awareness training programs. The objective of the training programs was to provide employees with a general knowledge of identified environmental topics to improve both personal and company environmental performance. Training topics included, but were not limited to, Clean Water Act requirements, Clean Air Act requirements, storm water management, spill prevention control and countermeasure plans and requirements, solid waste management and handling, hazardous waste management, universal waste management, asbestos management, lead paint awareness, Responsible Care program, waste determination procedures and environmental management systems. The trainings were carried out in a variety of methods including traditional classroom based, computer based training, awareness brochures, educational correspondence, tool box talks and more. Training developed was designed based on the targeted audience and spanned from general topic awareness to more detailed trainings for those employees who have specific environmental related responsibilities. Based on client specifications, selected training programs were designed to be interactive; actively engaging the employees in the training program. Typically, these programs included sections which determined the trainees’ comprehension of the training.