How to Conduct aWorld Class

Environmental Audit

Presented by

Gary Vegh

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?

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.

What would you classify as a

World Class Environmental Audit?

“When auditors compliment you on your record keeping”

Change Your Viewpoint.

Environmental = Chemical Safety

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

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

How to Approach Environmental

Ultimate goals:

– Reduce time required for reporting

– Get back to H&S issues

– Achieve accuracy

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

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!

Systems: Backbone of Management

“You don’t want to be the machine.

You want to own the machine”

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?

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?

Let’s take a look at the typical game plan…

Lots of Disconnected Spreadsheets.Not Good.

The Alternative

Material & Facility Modeling

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?

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

Flagging Chemicals

Material & Facility Modeling

Your Materials Track 3 critical data sets:

1. The chemical contents of materials• CAS• Relevant chemical properties

2. Amount purchased

3. Amount used

What’s In Your Materials? Few ways to determine:

– Get data direct from suppliers

– Batch determination

– Scraped from SDSs (GHS – formerly MSDS)

Material Data Management Revision Tracking

– Archive old records (5 years minimum)

– Spreadsheets don’t archive

Your Facility Map out your facility processes

Look at each step in your manufacturing process

– Materials used

– Impacts to:• Air• Water• Waste

– Recycling

– Energy

Your Processes Look to understand

– Source of emissions/waste

– Effects of processes• Transfer efficiencies, emission

factors, etc.– Mass balance

– Pollution control devices• Stack tests

The Big Picture

What Your System Will Produce

Complete on-site chemical inventory

Amount of materials processed

Air, water & waste profiles

ProcessedProcessed

Potential Problems Problems if you don’t do things right

– Fines

– ECHO list (Stock market – NYC)

– More frequent Audits

– Shutdown

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

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

Auditor’s Mindset REMEMBER: Your Permit is a Contract

– Essentially “Permission to emit”

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

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?”

Biggest Problems an Auditor Faces

Poor record keeping

Company’s knowledge of

– Facility

– Permit(s)

Turnover in EH&S staff

– Business continuity

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!

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

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

In Case You Have a “Record”

How Your History Affects You

Bad reputation = prior violations.

Conducting more inspections on a more frequent basis.

BUT…. You are not treated differently

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”

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

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

Build Business Continuity To ensure continuity,

auditor’s recommend:

– Centralized system

– Easy to understand

– Keeps data in raw format

Complete Internal Audits Advantages of doing internal audits:

– Get more efficient

– Cut costs

– Be proactive

– Make your workplace safer

Questions?