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Gap Analysis &
Improvement Tactics for
your EH&S program
Onsite Support Service:
What do you need help with to stay in
compliance?
1. All lines are muted, use the chat panel for tech
issues.
2. Unanswered questions will be answered on
Twitter after the webinar.
3. Webinar recording and slides will be emailed to
you tomorrow morning.
Share With the Audience
Meet Your PresenterMike AlbertOnsite Support Services Manager, New England
www.linkedin.com/in/michaelalbert1
• Triumvirate for 6 ½ years
• Completed multiple gap analysis for
different size sites
• Manage multiple onsite teams at large
and small Institutions
• Insight through EH&S programs
• Program growth through knowledge in
EPA and state agencies
• Leader and Inovative services manager
for Triumvirate’s Onsite Support
Programs
Triumvirate’s helpful hints to
knowing your program better.
Gap Analysis and Improvement
Tactics. Understand compliance; save
time and money.
Our Key Message
It is great to know your
strengths, but it is better to
know your weakness…
and then fix them!
What Will You Learn?
What can this analysis offer for my company?
I think I am doing great! Why do I need this?
Top Talent = Top Results
If there is something I am missing, is it hard to
fix?
How many times do you run into a
roadblock and need external
sources to help you out?
1) Never – I can do it myself
2) 1-2 times a month
3) 1-2 times a week
4) Daily
5) All the time
Start With the Basics• What do I currently do to stay in
compliance?
• Who does it?
• How is it documented?
• How often do I check it make sure it is done?
• Is there a reminder that can be used?
• Does it need to be done?
Common Program Gaps
Waste
Inventory
Permits
Safety of People’s Environment
Emergency Response and Contingency Plan
Common Compliance Gaps
Waste
Inventory
Permits
Safety of People’s Environment
Emergency Response and Contingency Plan
Helpful Tip
Actually look at all
documents that you need,
don’t assume they exist
because you think or were
told…
Other Common Issues
Reactive or Proactive
Team or White Knight
Given a sinking ship?
Given an aircraft carrier?
Who do you call?
Safety of People’s
Environment
• Time and effort to assess all
potentially dangerous
environments
• ‘Exposure’
• Overall safety and security of
the site
• Equipment or Engineering
control failure
• Proper Administrative and
PPE compliance
Costs of Plans and
Permits• Time, effort = $ or $$$
• Knowledge and
Experience
• Costs for submittals,
renewals
• Full understanding of
site
Helpful tip – proving by
experience or knowledge from a
fellow experience will help get
‘smaller’ numbers passed
through the budget
Cost of Inventory, Waste and Compliance
Inventory costs
money to complete
What comes in must go
out
HAP report
Other Cost Factors• Size of your institution or
site
• What is in place already
• What you need to know
more about
• How often you scratch your
head and wonder, what if…
Cost Savings With a Strong Program
Fines and newspaper articles hurt more:• The U.S. EPA, the U.S. Department of
Justice, and the State of Ohio a Clean Water Act settlement…to resolve claims that untreated sewer discharges were released into the Ottawa River during wet weather.
• The U.S. EPA announced a West Virginia-based metal recycler, has agreed to implement extensive, company-wide safeguards to prevent future accidental releases of hazardous chemicals from its facilities, resolving alleged Clean Air Act violations (CAA) stemming from an explosion at the company’s W. Va. facility that killed three people.
• Fined $205,000 for Hazardous Waste Violations
Case Study Example• A simple conversation with a large
Biotech company…• Who, what, where, how…
• “Environmental Resource”• You don’t have…what about…
• Outcomes:• SAA and CAA program
• All signs/labels/storage up to date
• Designed proper CAA’s for the entire site
• Designed safe procedures for moving waste across a very large campus
Quick and Easy Improvements
Implement Regular Site
Walks
Processes People are Completing
Unmarked Containers
Trash Receptacles
Outside Grounds
Public Interaction
Continue to Review
and Update…
• Permits and Plans
• Emergency
Procedures
• Clean Air Act
• Clean Water Act
• Standard Operating
Procedure’s
• Blood Born Pathogens
• Safety Protocol’s
Case Study• You get an unexpected
call from your…
• Local State Agency
• Coming in to inspect
tomorrow and want to
review the previous
inspection
• Let’s check
• Main Accumulation
Storage Area’s
• Satellite Accumulation
Area’s
• Paperwork for disposal
• Sewer discharge permit
• Air permits (generators)
Case Study• Outcomes from a smaller
community based company
• Chance to follow up with over generating of waste from a 3 month period (refile, make clear, report when project was completed)
• Updated and documented some SAA issues (very common)
• Buttoned up and cleaned up Universal Waste area
• Scheduled work and follow up with missing discharge sampling reports
Case Study 3: Onsite Program
1) When an onsite program is in place1) Up to date with your program
2) Feel confident about inspection (Still initial
shock)
3) Focus on what needs to be done
2) Passed inspection!
3) 180 degree change from years prior1) Minor issues found
2) Everything documented and fixed before
follow up
3) Learned for the future
Case Study 3: Outcomes
OutcomesPassed inspection!
Know your local state agency representative
A chance to impress this person
Follow up items included
• Fixing some SAA’s
• Adjusting CAA storage arrangement to
better communicate hazards
• Posting extra signs in the CAA
• Making a plan to fix a generator and
emissions issue
Action PlanObserve and make changes to
some immediate issues that improves your program
Take the survey
Reach out for more resources when you hit a roadblock
Do you need some sort of customized Onsite Support
Program?
Fully Integrated Onsite Support Program
1) Why is Triumvirate efficient, effective
and innovative?
2) What makes our people unique and
top notch?
3) Why we make the biggest
difference as a partner in your
compliance world.
Want to dig deeper into Triumvirate’s Fully
Integrated Onsite Program Opportunities?
Thank You For Attending!• You will receive an email
tomorrow with a copy of
this presentation
• Please complete our
short survey
• Register for future
webinars at
http://www.triumvirate.co
m/training/events
• Expect a transcribed copy
of the Q&A as well as a
special offer.