By: Amy Bauer
No matter the type of industry or size of facility, EHS Support commonly identifies a number of environmental, health, and safety (EH&S) compliance issues when visiting sites. These issues include:
- Mismanagement of universal waste or no program at all
- Inaccurate environmental plans (Spill Prevention, Control, and Countermeasure [SPCC], Stormwater Pollution Prevention Plan [SWPPP]) or no plan
- Inaccurate or missing labels on chemical and waste containers
- Sinks, floor drains, and other types of wastewater discharge to stormwater (e.g., pipes leaving a building)
- No tank registrations, inspections, or testing
- No leak rate recordkeeping and reporting for applicable refrigeration units
- Poor housekeeping
- Improper electrical wiring
- Missing lockout / tagout process
- Presence of fall hazards
- Unidentified confined spaces
- Combustible dust
- Improper or lack of personal protective equipment (PPE) (respirators)
- Missing machine guarding
Whether it be limited resources and tools, not having a comprehensive EH&S system, integration challenges, or just a general lack of awareness, these issues continuously occur and can add up. Certain areas of a facility, such as maintenance areas, are prone to any (and all) of these issues. Companies are not exempt from these programs based on type of industry, the size of the operation, or number of employees; all of these programs could apply.
A focused approach to EH&S compliance, by establishing a comprehensive system implemented at a reasonable cost, makes sense. It will not only keep the company out of trouble by preventing runaway expenses, violations, and loss of a positive corporate reputation, it is a smarter option than applying makeshift solutions that may lead to more problems.
Part of a comprehensive framework for an EH&S management program, beyond that firm commitment to the environment and human health, is evaluating (i.e., auditing) and communicating the results. Evaluations or audits can be media-specific for serious issues or can be a comprehensive review of an organization’s EH&S program. Compliance evaluations can be as simple as asking an employee to review their designated area on a continuous basis, or as involved as allowing a specialist to come to the site and identify what is wrong. Why would you want that? Change “specialist” to “environmental agency” and you have your answer.
Do any of the following photos look familiar? For more information on how EHS Support can help you identify potential EH&S issues and develop a comprehensive system, please contact Amy Bauer at 251-533-6949 or amy.bauer@ehs-support.com.
ABOUT THE AUTHOR: Amy Bauer has 20 years of experience conducting and managing environmental site assessments, regulatory compliance audits, environmental investigations, and regulatory compliance support. Amy specializes in assisting clients in interpreting and implementing various regulatory compliance requirements, and providing guidance and support for interactions with regulatory agencies… Read More
