This confidential client is an explosives manufacturer with 30+ manufacturing and distribution locations throughout the United States, Australia, and Mexico. The company has over 3,000 employees, manufactures over 54 million pounds of packaged explosives, and has more than 1.2 million tons of ammonium nitrate capacity.
EHS Support was retained by the client to perform comprehensive environmental compliance assessments of eight facilities throughout the United States. The assessments evaluated compliance with federal, state, and local environmental laws and regulations. Assessments met the requirements specified in the Standard Practice for Environmental Regulatory Compliance Audits (ASTM E2107-06). The auditor focused on the following environmental statutes and regulations:
- Resource Conservation and Recovery Act (RCRA)
- Clean Air Act (CAA)
- Emergency Planning and Community Right-to-Know Act (EPCRA)
- Clean Water Act (CWA) / Oil Pollution Act (OPA)
- National Pollutant Discharge Elimination System (NPDES)
- General pretreatment regulations for existing and new sources of pollution
- Spill Prevention, Control, and Countermeasure (SPCC) Rule
- Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) under Superfund Amendments and Reauthorization Act (SARA) / RCRA Corrective Action / Other Remediation
- Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
- Safe Drinking Water Act (SDWA)
- Toxic Substances Control Act (TSCA)
EHS Support’s audits identified compliance risks at the subject properties. The audit information helped the client evaluate the business risks associated with environmental compliance liabilities, which allowed for strategic decision making and corrective actions to protect the company from potential regulatory compliance issues.