Overview of Management Systems Used By EHS Professionals

Overview of Management Systems For EHS Professionals

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Five Avoidable Hazardous Waste Compliance Violations

EPA, State and local agencies regularly inspect hazardous waste generators to determine compliance with the hazardous waste regulations and laws. Listed below are some of the most common hazardous waste rule violations observed by inspectors during compliance inspections along with some tips for how to avoid those violations.

1. Waste Evaluation

Violation: Disposing of unevaluated or inadequately evaluated products or materials used at your site as nonhazardous waste.

You can use generator knowledge to assume your waste is hazardous, but you may need to test your waste for certain characteristics or properties such as heavy metals, flashpoint, pH and VOCs, to show it is nonhazardous.


Industrial Waste Disposal Burn Pit Observed During Inspection




Abandoned Chemical Products Stored In Lieu Of Disposal

2. Labeling

Violation: Missing or illegible waste description, generator information, accumulation start dates and other required information.

Hazardous waste containers must be labeled with the words “Hazardous Waste,” a description of the waste and the accumulation start date.


Mislabeled Mercury Waste Drum Identified During RCRA Audit

3. Open Container

Violation: Though funnel is covered, it is not designed with a closure device to withhold contents if overturned.

Container must be closed and have a closure device that is designed to withhold contents if container is overturned.



Waste Audit Finds Improper Flammable Waste Storage And Labeling

4. Universal Waste Lamp and Battery Management

Violation: Lamps (intact or broken) and regulated batteries are not stored in appropriate containers.

5. Record keeping

Violation: Evaluation records not kept at the licensed site or made easily available for inspection.

Violation: Missing or incomplete SQG or LQG training records for hazardous waste personnel.


Leaking Waste Drums Discovered During Facility Inspection

Compliance Audit For Atlanta Chemical Packaging Plant

Caltha LLP Project Summary

Project: Multi-media Environmental Compliance Audit
Client: Chemical Repackaging Plant
Location(s): Georgia

Key Elements: Compliance audit

Overview: Caltha preformed a multimedia compliance audits for this chemical mixing and repackaging operation located near Atlanta, Georgia. The scope of the audit included Federal, State, County and City requirements in addition to company policies and industry standards applicable to the operations environmental aspects. Regulatory programs addressed in the audit included:

OSHA
Hazard Communication

EPCRA
EPCRA 311-312,
EPCRA 313

Hazardous and Solid Waste Management
Federal RCRA rules
State waste rules
Universal waste rules

Clean Air Act
Federal air emission rules
Federal NESHAP standards
Federal RMP rule
Site air emission permit
State air emission rules

Clean Water Act
Authorized/Unauthorized Discharges
Stormwater Discharge NEC compliance
SPCC Rule Compliance
Spill Notification and Reporting
Federal Industrial pretreatment rules
Industrial discharger permit

TSCA
Current registration
Inventory Update Rule IUR Reporting
Chemical Data Rule CDR Reporting

Tanks
Aboveground tank rules
Underground tank rules


Aboveground Product Vessels


For more information on Caltha LLP services, go to the Caltha Contact Page

 

Caltha LLP | Your EHS Compliance, Auditing 

and EMS/SMS Partner

Risk Management Plan Requirements Delayed

In January 2017, EPA published amendments to the Risk Management Program (RMP) Rule 40 CFR Part 68. The amendments included requirements for:

• Root cause analysis as part of an incident investigation;
• Independent third-party compliance audits following a release event reportable under RMP or when an agency requires it based on site conditions;
• Inclusion of a safer technology and alternatives analysis as part of the process hazard analysis for processes in North American Industry Classification System (NAICS) codes 322, 324, and 325 (manufacturing of Paper, Petroleum and Coal Products, and Chemicals);
• Emergency response enhancements such as annual coordination with local emergency response agencies, annual testing of emergency notification procedures, and full field exercises at least every 10 years for responding facilities; and
• Measures to increase availability of chemical hazard information to the public.

Aboveground Product Vessels



Following publication of the amendments, EPA received several petitions for reconsideration and request for stay of the amendments. On June 9, 2017, the EPA Administrator signed a final rule to delay the effective date of the RMP rule amendments until February 19, 2019.





Caltha LLP | Your Safety and Health Compliance
Management Partner

Sanitation Certification Self Audit Checklist

Many business sectors require assurance of sanitary conditions, either to meet regulatory or industry standards, or to manage the risks of negative outcomes from not meeting minimum sanitation goals. These include health care sectors, medical device sector, food sectors, hospitality sectors or any other facility where employees or customers could come in contact with microbes on clothing, linen, equipment, work surfaces and other media.

Defining Underlying Business Risk

Some businesses rely on an external or internal certification to demonstrate they have adequately controlled risks associated with sanitation. Internal or external auditors will often review these certifications, noting the presence or absence of a current certificate. However, the business risk to be controlled is not simply the absence of a certificate, but the presence of less than sanitary conditions (i.e., not meeting the objective of maintaining sanitation above established criteria).

Sanitation Certification Self-Audit Checklist

To evaluate the underlying business risk and controls, the review of a certificate should be followed up with a review of the underlying data and control systems. Below are some suggested self-audit questions which could be used to assist in evaluating the business control systems in place related to sanitation certifications:

• Is a formal certification document required by either regulation or company policy? Does the certificate contain all required elements? Is it current?
• Is the entity issuing the certification independent of the process? i.e, is the certificate issued by the same company or department performing the sanitation?
• Have quantifiable criteria been established?
• Are underlying data available for review and do they support the certification?
• How were samples collected? Does sample collection procedure ensure representative sampling of the materials or media being certified?
• How are samples tested? Has an accepted laboratory method been used? Has appropriate chain of custody been documented?
• Is the testing entity independent of the sanitation process? i.e, is testing done by the same company performing the sanitation or providing sanitation chemicals being evaluated?

By evaluating the overall system in place to ensure sanitation, rather than just the presence of a certificate, the internal auditor can provide much better insights on the reliability of the system to ensure that sanitation goals are being achieved consistently.


Caltha LLP provides certified auditors to conduct third party audits, including vendor/contractor audits. Click here to review examples of past auditing projects.

EHS Compliance Audit In Manchester, NH

Caltha LLP Project Summary

Project: Environmental - Safety Compliance Audit
Client: National Industrial Corporation
Location(s): Manchester, New Hampshire

Key Elements: EH&S audit, LQG, hazardous waste treatment permit, air permit, hazardous material storage, wastewater permit, hazard communication, SPCC

Overview: Caltha LLP conducted a multimedia environmental, health and safety audit of this industrial facility located in New Hampshire. The scope of the audit included:

• EPCRA hazardous chemical storage reporting
• Hazardous waste management - Large Quantity Generator
• Hazardous waste treatment permit
• Current air pollution control permit
• Current industrial wastewater discharge permit
• TSCA
• Tanks
• Hazard communication
• DOT Hazardous material transportation
• Groundwater remediation permit

The audit was led by a IIA-certified professional auditor.

Click here to review other example Caltha EH&S auditing projects. Click here to review other Caltha projects in New Hampshire and NH regulatory updates.

Business Related Environmental Risks Compared To Real Estate Risks

EHS Auditors To Supplement Audit Teams Or Fill Subject Matter Expert Roles

Caltha LLP has environmental and safety compliance and management system auditors available for short-term assignments to supplement audit teams or to provide Subject Matter Experts for auditing projects. Click here to review recent audit project examples.

Caltha staff have experience conducting EH&S audits in most US States and Canada. Caltha also has performed media or regulatory specific audits, including:

• Product stewardship audits
• Product responsibility audits
• Waste - hazardous waste audits
• TSCA audits
• Air permit compliance audits
• Wastewater compliance audits
• Tank compliance audits
• Risk Management Plan audits

For more information on the availability of short-term auditors to supplement audit teams or to full specific SME roles, contact Caltha at info@calthacompany.com

Alabama Mutimedia Compliance Assessment Conducted By Certified Auditor

Caltha LLP Project Summary

Project: Environmental and Safety Compliance Audit
Client: National Industrial Corporation
Location(s): Mobile, Alabama

Key Elements: EH&S audit, hazardous waste, air permit, hazardous material, wastewater permit, hazard communication, emergency response preparedness

Overview: Caltha LLP conducted a multimedia environmental, health and safety audit of this industrial facility located in the Mobile, Alabama area. The scope of the audit included:

• EPCRA hazardous chemical storage reporting
• Hazardous and Solid Waste Management
• Current ADEM. air permit
• Current industrial wastewater pretreatment permit
• Industrial stormwater BMP rules
• TSCA
• Tanks
• Hazard communication
• DOT Hazardous material transportation

The audit was led by a IIA-certified professional auditor.

Click here to review other example Caltha EH&S auditing projects. Click here to review other Caltha projects in Alabama and AL regulatory updates.

Overview of Environmental and Safety Consultant Services

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Certified Environmental and Safety Audit in Raleigh

Caltha LLP Project Summary

Project: Multimedia EH&S Compliance Audit
Client: National Corporation
Location(s): Raleigh-Durham Region, North Carolina

Key Elements: EH&S audit, hazardous waste, air permit, hazardous material storage, wastewater permit, hazard communication

Overview: Caltha staff conducted a multimedia environmental, health and safety audit of this industrial facility located in Raleigh-Durham Region. The scope of the audit included:

• EPCRA
• Hazardous and Solid Waste Management- 15A NCAC 13B
• Current NC Air Permit
• NC Air Pollution Control Rule – NCAC 15A-2D
• Current wastewater discharge permit
• TSCA
• Tanks
• Hazard communication
• DOT Hazardous material transportation

The audit was led by a IIA-certified professional auditor.


Click here to review other example Caltha EH&S auditing projects. Click here to review other Caltha projects in North Carolina and NC regulatory updates.

Charlotte Facility Needed Audit For Compliance Improvement

Caltha LLP Project Summary

Project: Compliance Audit
Client: National Industrial Corporation
Location(s): Charlotte, North Carolina

Key Elements: EH&S audit, hazardous waste, air permit, hazardous material storage, wastewater permit, hazard communication

Overview: Caltha staff conducted a multimedia environmental, health and safety audit of this industrial facility located in Charlotte, NC. The scope of the audit included:

• EPCRA
• Hazardous waste rules as applicable to RCRA Conditionally Exempt Small Quantity Generator (CESQG), and Solid Waste Management rules including Mecklenburg County Mandatory Source Separation Ordinance (SSO) and 15A NCAC 13B
• Current NC Air Permit
• Current Charlotte-Mecklenburg Utility Department industrial wastewater discharge permit
• TSCA
• Tanks
• Hazard communication
• DOT Hazardous material transportation

The audit was led by a IIA-certified professional auditor.

Click here to review other example Caltha EH&S auditing projects. Click here to review other Caltha projects in North Carolina and NC regulatory updates.

Certified Environmental Health and Safety Audit Services

Caltha LLP provides IAA-BEAC certified auditors to perform internal EH&S audits to support ISO 14001 registered organizations or to support routine internal audit programs implemented as part of an overall governance system. Caltha can provide:

• Single auditors to support audit teams as a media or regulatory expert,
• Audit teams to address multiple program areas, or
• Due diligence auditors / audit teams.

Caltha auditors can act as adjunct auditors to augment your existing internal audit team, or can act as an independent third party auditor.


Caltha auditors have conducted assessments in all 50 US States, Canada, Mexico, South America, Europe and Asia.


Click here for more information on Caltha Compliance Audit, Management System Audit and Due Diligence Assessment services

Chicago Multimedia Compliance Audit For Manufacturing Plant

Caltha LLP Project Summary

Project: HSE Compliance Audit
Client: High Tech Manufacturer
Location(s): Chicago, Illinois

Key Elements: EH&S audit, hazardous waste, air permit, hazardous material storage, wastewater permit, PPE assessment, hazard communication


Overview: Caltha LLP conducted a multimedia environmental, health and safety audit of this manufacturing facility located in Cook County. The scope of the audit included:

• EPCRA
• Hazardous and Solid Waste Management
• Current IEPA Air Permit
• Cook County Air Emission Ordinance
• Current wastewater discharge permit
• TSCA
• Tanks
• Hazard communication
• DOT Hazardous material transportation

The audit was led by a IIA-certified professional auditor.

For more information on Caltha LLP services, go to the Caltha Contact Page

Overview of EHS Management Systems For The Hazardous Materials Manager - EH&S Compliance Professional

The link below provides training slides from the CHMM Review Course on Environmental Management Systems (EMS) and Health & Safety Management Systems.

Presentation Slides: EHS Management Systems Overview for the Hazardous Materials Professional

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Environmental Compliance Training, Waste Management Training, SPCC Training

Caltha LLP provides a wide range of training programs to industrial and government sector clients to meet the requirements of State and EPA rules, permits and related spill and emergency preparedness rules. Training can be provided to large or small groups and is provided either in person at your location, or through a live webinar format. For further information and to request a quote, go to Employer's Environmental Health and Safety Training Center.


The training sessions commonly requested include:

• Hazardous waste management training
• SPCC annual training
• Spill response training
• DOT hazardous material (HazMat) triennial recertification and initial training
• Facility compliance training overview (covering a wide range of typical facility environmental compliance topics)
• Internal compliance auditor training
• Industrial and construction site stormwater discharge permit training
• Stormwater monitoring training
• Training for site inspections

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Multimedia Compliance Audits, Management System Audits, EHS Audits

Brief project summaries for consulting work completed by Caltha LLP. Project summaries archived here include compliance audits, multimedia audits, regulatory program audits, including air rule audits, hazardous waste - RCRA audits, wastewater and stormwater discharge audits, TSCA audits, EHS audits, safety audits, product stewardship, product responsibility audits, energy audits, EMS audits, management system audits, audit training and others.


Click here to see a summary of projects completed by Caltha LLP related to compliance audits, multimedia audits, regulatory program audits, air rule audits, hazardous waste, RCRA audits, wastewater and stormwater discharge audits, TSCA audits, EHS audits, safety audits, product stewardship, product responsibility audits, energy audits, EMS audits, management system audits.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Regulatory Compliance Audit and Due Diligence For Minnesota and North Dakota Food Manufacturing Plants

Caltha LLP Project Summary

Project: Compliance Audit and Environmental Due Diligence For Minnesota and North Dakota Food Manufacturing Plants
Client: International Food Manufacturing Industry
Location(s): Minnesota and North Dakota

Key Elements: Environmental Compliance Audit, Phase 1 Environmental Site Assessment

Overview: Caltha was retained by this multinational food manufacturer to conduct an environmental regulatory compliance audit and a Phase I ESA at two of its plants located near Minneapolis, Minnesota and near Bismarck, North Dakota. Compliance audits were conducted to assess compliance with EPA, Minnesota Pollution Control Agency (MPCA), and Hennepin County requirements in Minnesota, and EPA and North Dakota Department of Health (NDDH) requirements in North Dakota. Regulatory requirements evaluated included:

• Clean Air Act,
• Clean Water Act,
• RCRA hazardous waste and solid waste requirements,
• Emergency Preparedness and Community Right-to-know Act (EPCRA) requirements,
• Toxic Substance Control Act,
• Above and underground tank requirements,
• OSHA Hazard Communication.

Caltha also completed a Phase I Environmental Site Assessment (ESA) for both sites, in accordance with ASTM E1527-05.



For more information on Caltha LLP services, go to the Caltha Audit Page

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

 

RCRA and TSCA Compliance Audit For Multiple Facilities To Meet ISO 14001 Requirements

Caltha LLP Project Summary

Project: Combined RCRA and TSCA PCB Management Audit For 26 Facilities
Client: Electric Utility
Location(s): 26 locations

Key Elements: RCRA hazardous waste audit, TSCA PCB management, Used oil management, Universal waste management, ISO 14001

Overview: Caltha was retained to conduct a compliance audit of 26 facilities to assess compliance with:

• EPA hazardous waste rules (40 CFR Part 260-262)
• Minnesota hazardous waste rules (MPCA Chapter 7045)
• North Dakota hazardous waste rules
• Federal and State requirements for used oil management (40 CFR Part 279)
• Federal and State requirements for universal waste management (40 CFR Part 273)
• EPA Toxic Substances Control Act (TSCA) requirements for PBC management (40 CFR Part 261)

Audits were conducted to satisfy ISO 14001 standards for scheduled audits, under ISO 14001 clause 4.5.2.1. Audits were completed with a combination of records review and on-site inspections.



For more information on Caltha LLP auditing services, go to the Caltha Compliance and EMS SMS Audit Page



Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

 

Environmental Compliance Audit For Iowa Food Ingredient Manufacturer

Caltha LLP Project Summary

Project: EHS Compliance Audit For Iowa Food Ingredient Manufacturer
Client: Food Ingredient Manufacturer
Location(s): Iowa

Key Elements: Multi-media Compliance Audit

Overview:

Caltha was retained by this food ingredient manufacturer to conduct a multi-media compliance audit of its operations located in northwest Iowa. The operations were self certified as being in conformance with the Environmental Management System (EMS) requirements specified under ISO 14001. The audit was being conducted in advance of a planned merger and was required by the prospective business partner.

The scope of the compliance audit included applicable Federal, State and local regulations:

OSHA	Hazard Communication
EPCRA	EPCRA 311-312 EPCRA 313
Hazardous and Solid Waste Management	Federal RCRA rules
	Iowa waste rules
	Universal waste rules
Air	Federal air emission rules
	Federal NESHAP standards
	Iowa air emission permit
	Iowa air emission rules
Clean Water Act	Authorized/Unauthorized Discharges
	Iowa Stormwater Discharge Permit compliance
	SPCC Rule Compliance
	Iowa Spill Notification and Reporting
	Federal Industrial pretreatment rules
	Local Industrial discharger permit compliance
TSCA	Current registration
	Inventory Update Rule IUR Reporting
	Chemical Data Rule CDR Reporting
Tanks	Iowa aboveground tank rules
	Iowa underground tank rules

The audit was completed under attorney client privilege through external legal counsel.



For more information on Caltha LLP services, go to the Caltha Contact Page

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.
 For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website