No other industry is regulated as heavily as the manufacturing industry when it comes to environmental regulatory liability. Depending on your site’s operations, it might have air permits, a wastewater permit, a stormwater permit, hazardous waste, and chemical storage and use that require reporting.
However, even with such a heavy regulatory burden, EHS Managers often lack the time and resources to give environmental compliance the attention it deserves. As a result, health and safety usually take priority throughout the year, and sometimes environmental requirements get pushed to the side.
When noncompliance can have devastating consequences for businesses, employees, surrounding areas, and the environment, this careless approach towards environmental compliance is simply unacceptable. Companies need to take a hard look at how they manage the process to identify the strengths and weaknesses within their current program.
What to Look For During an Environmental Review
An annual review, preferably at the end of the calendar year, is a great way to evaluate your environmental programs, ensure that you are in compliance, and plan for any upcoming compliance requirements in the new year. Identifying issues now, during an annual review, and proactively working to remedy them can save you from EPA inspections and violations in the future.
Here are five areas to inspect during your next environmental compliance review:
- Look for pattern changes or differences in the amount of hazardous and non-hazardous waste and wastewater and stormwater generated during the year. If you identify any discrepancies in your annual data or have exceeded permit limits, you should investigate these issues and resolve them. Are these changes indicative of a problem with monitoring equipment or a process change?
- Evaluate process changes that have occurred over the past year or may happen soon. Process changes can significantly impact emissions and the waste your site generates. Therefore, evaluating any changes before they occur is essential to determine if they affect your existing permits or require you to obtain new ones.
- Inspect and ensure that any control or monitoring equipment is functioning correctly with the help of facility, maintenance, or site operations personnel. Damaged or off-line control equipment can cause emissions that exceed permit limitations, and broken monitoring equipment, such as a flow meter, can cause inaccurate readings.
- Ensure chemical records are appropriately managed, and key stakeholders have access to the records in the event of an unscheduled regulatory audit. Proactively preparing documents for an inspection or audit can minimize or even eliminate violations from a regulatory agency.
- Identify which permits are up for renewal the following year and create a plan to gather all necessary information. Renewal applications often need to be submitted six months to one year before expiration and require significant time and information to complete. This process is also a great time to gather the information necessary for any upcoming reporting, such as hazardous waste, annual permits, or chemical reporting.
Finding the Time for an Environmental Review
When you complete an annual review, you create an opportunity to catch anything that fell through the cracks and identify upcoming events. However, finding the time can be tricky when most EHS professionals are already spread thin.
Many manufacturing facilities schedule shut-downs or slow production around the holidays, which makes it the perfect time to audit your environmental programs, organize documentation, and plan for the upcoming year.
Even if the end of the year isn’t slow at your facility, you should still prioritize an annual environmental compliance review. When done correctly, a yearly review is a powerful tool that can identify issues early, allowing you to correct them before they become significant noncompliance issues.
Encamp can help. For companies within the manufacturing industry, ensuring that your records and facility are ready for an unannounced inspection or audit is critical to maintaining the health of your business. However, correctly maintaining the documentation and everything else that goes into preserving environmental compliance is challenging.
Encamp solves the complexity of environmental compliance with high-tech solutions and high-touch expert support and is on a mission to create a world where good for business can equal good for the environment. We help enterprises transform compliance programs and human processes into a technology-driven system that lays the foundation for accurate and ongoing environmental compliance. Request a demo to learn more.
Jenn Mester
Jenn joined Encamp in 2022 with more than 15 years of environmental compliance experience. Prior to joining Encamp, she spent three years as the head of the Environmental Department for the City of Cleveland, Department of Public Utilities, where she managed a team of HazMat professionals and oversaw all aspects of environmental compliance for a large electric, water, and sewer utility. She also has experience as an EHS Manager in the chemical and biochemical sectors, and eight years of experience in Environmental Consulting. Jenn maintains certification as a Certified Hazardous Materials Manager (CHMM). She is passionate about protecting the environment, understanding complex environmental regulations, and helping companies achieve compliance with these regulations.
