Introduction to Managing US Environmental Regulation and safety

By HSP

Managing environmental and safety issues in US is challenging, time consuming, and expensive. Harm to people or the environment is difficult to prove so regulations are increasingly designed to eliminate contamination. Effluent standards are based on health effects studies but because of factors such as cancer’s long latency period, and the lack of human exposure data, standards generally include a large safety factor. The environmental manager must recognize that there is little margin for error when it comes to contamination issues.  The safety manager is called upon to manage both risk and resources.

Managing hazardous materials generally involves the following four major issues: identification (air and water emissions, rinsewaters, spent raw materials, etc.), storage and handling, disposal and shipping, and recordkeeping. An industrial facility that does not have programs addressing all four of these issues should essentially not be handling hazardous materials.

The environmental and health-safety manager must know what his or her facility is purchasing, generating, storing, treating and disposing of in order to effectively satisfy the “cradle to grave” provisions of RCRA (Resource Conservation and Recovery Act). Good recordkeeping and communication are essential to several key elements of any pollution control and prevention program: emergency procedures, contingency planning and employee training. Pollutant Discharge Elimination System) violation and how large can the spill be before it constitutes a reportable quantity (RQ) under CERCLA (Comprehensive Environmental Response Compensation and Liability Act)?

Well run organizations are those which have established formal Safety and Hazardous Materials Management Programs. These programs establish corporate policy, which addresses pertinent aspects of OSHA (Occupational Safety and Health Act), TSCA (Toxic Substances Control Act), CERCLA, SARA (Superfund Amendments and Reauthorization Act), RCRA, the Hazardous Materials Transportation Act (HMTA), and other applicable regulations. OSHA regulations could be violated because precautions for employee exposure are not taken, SARA could be violated because the requirement for notification of the presence of listed material has not been met, and RCRA regulations could be violated if waste from the material is not stored or disposed of properly.

The Occupational Safety Professional (OSP) must become integrated into all aspects of a facility’s operations. A properly informed OSP helps limit the amount of a hazardous material stored onsite, monitors the use of the material so that right-to-know regulations are not violated, and assesses the rate at which a waste is generated to minimize spill potential and storage and disposal difficulties.

Waste minimization requirements and the land disposal ban are making waste production more expensive. There must be spill containment, supplies for cleanup, controlled access, and segregation of incompatible materials. Both on-the-job training and a written training program are necessary. Fines may result if the training is not properly documented and employees are not tested for competency.

A company cannot control pollution or its hazardous wastes by selling contaminated properties or assets, however, it can certainly add to its liabilities by purchasing contaminated property. Unfortunately, many companies already own contaminated property with projected remedial actions that may cost millions of dollars.

The OSP may be called upon to plan, negotiate, and manage these expensive, and complicated hazardous waste cleanups. Contract documents must be precise and accurate. hazardous material stored onsite, monitors the use of the material so that something goes wrong such as a spill, a fire, or explosion.

(Summary from ENVIRONMENTALAND HEALTH & SAFETY MANAGEMENT – A Guide to Compliance, page 1-3), Nicholas P. Cheremisinoff, Ph.D. Madelyn L. Graffa)

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