Embed Size (px)
Citation preview
World-Class EH&S Data Management and Planning:
A Material and Facility Modelling Methodology
Gary Vegh, ERA Environmental Management Solutions
How to Conduct a
World Class Environmental Audit
Presented by
Gary Vegh
To StartShow of hands for:• Health & Safety Professionals?• Environmental Professionals?• If Health & Safety is a bigger priority at your
business?• If you find 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.
How would you classify a World Class Environmental Audit?
“When auditors compliment you on your record keeping”
How to Re-frame “Environmental” For Success
Change Your Viewpoint.
Environmental = Chemical Safety
How to Re-frame “Environmental” For Success It is simply another form of H&S:
– Designed to keep people safe.
– Key environmental reports designed for safety.
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
Key Environmental Reports
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 21 + Years Experience
Boils the problem down to 2 questions1. Which materials am I using?
2. What goes on in my processes?
4 Pillars for a Successful System
1. Material & Facility Modeling2. One database, multiple outputs3. World class environmental
record keeping1. Accurate2. Transparent3. Keep data in “raw” format
4. List of applicable regulations
Flagging Chemicals
On-site inventory
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)
– Metlzer Case Example
– 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
How to Conduct aWorld Class
Environmental Audit
How to Conduct aWorld Class
Environmental Audit
How to Conduct aWorld Class
Environmental Audit
How to Conduct aWorld Class
Environmental Audit
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
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?
Conference participants are eligible for up to 13 contact hours 1.3 CEUs. Forms will be available after lunch on Wednesday at the
registration are.
Return completed forms at the conclusion of the conference.
Please remember to fill out the conference survey. This will be sent to you by email.
https://www.surveymonkey.com/r/2015OGENV
World-Class EH&S Data Management and Planning:
A Material and Facility Modelling Methodology
Gary Vegh, ERA Environmental Management Solutions
