The responsibilities of an entry supervisor for a confined space are:
- Know space hazards including information on the mode of exposure, signs or symptoms and the consequences of exposure
- Verify emergency plans and specified entry conditions such as permits, tests, procedures and equipment before allowing entry
- Terminate entry and cancel permits when entry operations are completed or if a new condition exists
- Verify that rescue services are available and that the means for summoning them are operable
- Take appropriate measures to remove unauthorized entrants
- Ensure that the entry operations remain consistent with the entry permit and that acceptable entry conditions are maintained
Is the entry supervisor at your facility aware of these responsibilities or could he/she use additional training? Call one of the Environmental Health and Safety Compliance technicians at August Mack Environmental at 800.579.0770 if you have these types of training needs!
An Environmental Management System (EMS) is the business processes an organization uses to understand and manage their effect on the environment. An EMS follows the Plan - Do - Check - Act process (PDCA). The graphic below illustrates this process.
How is your safety program? Are the plans and programs up-to-date? Have you completed the required training? Have you spot checked or audited your programs? Are you documenting adherence to the requirements? If you are not sure, consider performing a safety compliance audit by a third party. Call August Mack Environmental at 317.916.3105 for more information!
An environmental compliance consultant specialist from August Mack Environmental is likely to ask the following questions regarding SPCC Plan during the environmental compliance auditing process:
- Do they have or do they need a SPCC Plan?
- Is it updated? Are they following it? Is it PE-certified? Does the plan have all of the necessary elements?
- Where are spill kits located?
The environmental compliance consultant from August Mack Environmental also will:
- Review all record keeping
- Look at all oil storage areas
- Look at housekeeping
August Mack Environmental, Inc., a full-service environmental, health and safety (EH&S) consulting firm, is pleased to the promotion of Bennett Thayer to Office Manager for the Dublin, Ohio office. Since joining August Mack in 2004, Thayer has served as a field scientist, staff scientist and project manager.
With more than eight years of experience, Thayer specializes in local, state and federal environmental compliance; environmental, health and safety (EH&S) servicing and reporting; environmental management program development and implementation; biological assessment and environmental investigations; groundwater monitoring; subsurface investigations; underground storage tank (UST) closure; environmental site assessments; wetland determinations and delineations; remedial system operations and maintenance; work plan design and implementation; asbestos surveys; Storm Water Pollution Prevention Plan (SWPPP) preparation and implementation; and Spill Prevention, Control and Countermeasures (SPCC) Plan preparation and implementation. In his new role as an office manager, Thayer will be responsible for managing the office’s daily operations, providing technical oversight for projects and managing the office’s growing staff. According to Bryan Petriko, vice president and principal environmental engineer for August Mack, “During the past six years at August Mack, Ben has shown exemplary strength in leadership, technical knowledge, resource management and client management. These qualities made him an excellent choice for the Office Manager position of our Ohio office. I am confident that our Ohio office will continue to flourish under his leadership.”
Thayer received his Bachelor of Arts degree in Environmental Science from Otterbein College.
August Mack Environmental, Inc. is a full-service environmental, health and safety (EH&S) consulting firm specializing in regulatory compliance; environmental due diligence and risk management; site investigation/remediation/closure; and sustainability services to the industrial, legal, financial, health care and government sectors throughout North America. August Mack has offices in Indiana, Michigan, Missouri, Ohio and Pennsylvania. For more information on the company’s products and services, call 317.916.8000 or visit www.augustmack.com.
An environmental compliance consultant specialist from August Mack Environmental is likely to ask the following questions regarding storm water during the environmental compliance auditing process:
- Do they have or do they need a storm water permit?
- Is it updated? Are they following it? Does the plan have all of the necessary elements?
- Where are spill kits located?
- Any sampling requirements?
The environmental compliance consultant from August Mack Environmental also will:
- Review the Storm Water Pollution Prevention Plan (SWPPP)
- Review all record keeping and reports
- Look at “high risk” areas
- Look at housekeeping
An environmental compliance consultant specialist from August Mack Environmental is likely to ask the following questions regarding wastewater during the environmental compliance auditing process:
- Are they fulfilling the permit requirements?
- Are all reports being submitted on-time and correctly?
- Are all plans developed that are required in the permit (Slug Control Plan, etc.)? Are they following and updating plans, as necessary?
- Is record keeping being completed as required?
- When are the permits due to be renewed?
- Are there any planned expansions?
An environmental compliance consultant from August Mack Environmental also will:
- Look at all permitted discharges and processes.
- Look at discharges that are not permitted and determine whether or not they should be permitted.
- Review the analytical results, DMRs, etc.
An environmental compliance consultant specialist from August Mack Environmental is likely to ask the following questions regarding air during the environmental compliance auditing process:
- Is the facility fulfilling the permit requirements?
- Are all reports being submitted on-time and correctly?
- Are all plans developed that are required in the permit (CAM, ERP, OM&M, etc.)? Are they following and updating plans as necessary?
- Is record keeping being completed as required?
- Have stack tests been completed?
- When are the permits due to be renewed?
- Are there any planned expansions?
An environmental compliance consultant from August Mack Environmental also will:
- Look at all permitted equipment and processes (air emissions inventory)
- Look at equipment and processes that are not permitted. Should they be permitted?
- Inspect the roof and look at all stacks
- Review MSDS of any coatings, paints, etc.
As discussed in an earlier post, eCAP® has a five-step process that one of our environmental compliance specialists utilize to implement eCAP® at any facility. The second step in this process is compliance review and planning.
During the environmental, health and safety compliance review and planning process, the eCAP® account team will meet with your management team to review your current compliance status and make plans for the year ahead. We evaluate a wide range of variables, including potential new regulations, the possibility of facility process changes, increased production, capital improvements, reduced waste generation, increased energy efficiency and improved raw materials usage. Additionally, we develop customized audit protocols for routine inspections.
To learn more on how eCAP can help your facility maintain EPA environmental compliance and reduce the cost of environmental compliance programs, click here to read an article written by one of August Mack's technical experts.
While each environmental, health and safety (EH&S) audit is unique to the needs of the facility, the following list identifies the standard areas usually examined during the environmental compliance auditing process.
- Air
- Wastewater
- Storm Water
- SPCC Plan
- Waste Plan
- Chemical Reporting
- Other Compliance Issues
During the next few weeks, this blog will discuss these key areas and highlight what an environmental compliance specialist at August Mack Environmental would look for in each of these areas during the environmental compliance auditing process.
One important aspect of the environmental compliance auditing process is the review of the facility's records and data. During this review, an experienced environmental compliance consultant will review the following:
- Permits
- Environmental Plans
- Environmental Reports
- Record keeping and inspection documents
- Training documentation
- Regulatory agency correspondence
- Material Safety Data Sheets (MSDS)
- Purchasing records
The environmental compliance specialist also will suggest recommendations for any improvements regarding file organization and develop a corporate environmental compliance calendar.
When I meet with personnel at facilities that are given the responsibility of making sure the facility is compliant with all the federal and state environmental regulatory requirements, the focus always shifts to the difficult challenges. But I find it intriguing that they are so focused on these challenging issues that they often are overlooking and violating easy regulatory requirements. Many facilities need a SPCC Plan or a storm water permit but don't have one. Or they may not have evaluated the applicability of Tier Two reporting for their facility. Don't get so caught up in the difficult challenges that you forget about the typical environmental requirements.
If you need environmental compliance assistance, give me a call at 317.916.3105.
Given the recent events of a major oil spill, this is a very hot topic. Did you realize that if your facility has more than 1,320 gallons of aboveground oil storage (stored in container/tank sizes of 55 gallons or greater), that you are applicable to environmental regulations that require you to develop a plan? Call me, an environmental regulation compliance expert, if you need to learn more (317.916.3105).
eCAP® (Compliance Assurance Program) was designed to efficiently and effectively manage the environmental, health and safety compliance of any facility regardless of size or geographic location. Today, August Mack Environmental manages more than 60 facilities throughout the United States using its environmental management system known as eCAP®.
We are able to successfully implement this environmental compliance program at any facility due to our five step process:
- Environmental, Health and Safety Audit
- Compliance Review and Planning
- Site Inspections
- Electronic Record Keeping and Reporting
- Technical Support
During the next few weeks, this blog will discuss each of these five steps in-depth and highlight why eCAP® is a great option to consider for outsourcing your company's environmental, health and safety program.
Managing safety for a single facility can be a challenging and daunting task. To complicate things, if your company has multiple facilities you could be facing additional, less obvious, risks. The good news: knowing what to watch for and having a good system in place allows you to carry “lessons learned” from one facility to another. If your company operates multiple facilities, join us for this informative webinar on how to minimize your costs and risks associated with multiple facilities.
To register for this August 24th
Environmental Compliance Plan webinar, visit
augustmackevents.webex.com.
29 CFR 1910.38 (b) states: An emergency action plan must be in writing, kept in the workplace, and available to employees for review. However, an employer with 10 or fewer employees may communicate the plan orally to employees. Are you fulfilling this regulatory requirement if applicable?
August Mack specializes in environmental, health and safety compliance; environmental due diligence; environmental site remediation; and sustainable business strategies to the industrial, legal, financial, health care and government sectors throughout North America.
Powered by Compendium