“What If?” : How to Ace Unexpected Inspections
“Hello, my name is Bill Hess, and I represent Cornerstone Environmental, Health and Safety. Who is your EHS representative here on site?”
There are a surprising number of places that I “cold call” in person where the front desk employee has no clue who the Environmental, Health, and Safety (EHS) person is or the responsibilities that position holds. If I were an OSHA or Environmental Regulatory Inspector, that person and the company would be off to a very bad start to their day.
In my role with Cornerstone as Manager of Business Development for our Northern Midwest Region for the past 25 years, I have probably visited and prospected over a thousand sites in person. These visits are often unannounced, and I fit them in between other scheduled meetings that I have. Given the turnover rates that many companies experience these days, it’s really no surprise that the front desk person does not know the key people in their organization. However, the front desk person (if there is one) or whoever answers the lobby phone should be well informed of who the facility EHS Manager is and know how to reach them.
In the case of regulatory inspections, it is critical to get off to a good start. First impressions can set the tone of the entire day. Facility management has a responsibility to coach gatekeepers with how to handle an unannounced inspection, and how to manage the inspector until the appropriate EHS person can arrive to meet them. Understanding the importance of this initial interaction is crucial. A respectful and knowledgeable greeting shows the inspector that your organization takes compliance seriously.
Your EHS Manager should also be instructed as to how to manage the inspection. Some simple guidelines include:
Be Cooperative. Throughout the inspection process, your attitude should be one of cooperation. If corrective actions can be taken care of during the inspection, then get it done by you or someone else who is capable.
Just answer the question. Do not elaborate, tell stories, or reveal anything but what is asked or needed. “Loose Lips Sink Ships” is still true in 2024.
Stay on the path. Many inspectors are curious about your operations, but you need to keep them on the path to where they want to go or for what they want to see. This does not need to be a full-day tour unless they state that it is a wall-to-wall inspection.
Monitor pictures. If the inspector takes photos, they may need your permission if it involves proprietary technology or materials. Be sure to take the same pictures they have taken for your own defense.
Take good notes. You may be paying attention to everything during the inspection, but the written report you get from the inspector may take weeks for them to complete. Your notes should match their notes, so don’t rely on your memory for details.
Closing Conference. Be sure to address any questions that you have or that the inspector has during the closing conference. If additional information is needed, establish a date for when it can be delivered to the inspector.
In summary, be prepared and organized. Getting off to a good start could make your day.
Is Your Environmental Program Getting the Recognition It Deserves?
Companies have made significant strides over the past decades to achieve regulatory compliance. As of late, more and more businesses have been highlighted in the media for going above what is asked of them in an effort to become stewards for environmental consciousness. One of the most effective means to accomplish this goal is to implement an Environmental Management System (EMS). An EMS provides the framework to develop your system for maintaining compliance with environmental regulations by establishing a set of policies and procedures to follow. The EMS reduces the guesswork and unwanted actions that sometimes occur in daily operations which can lead to non-compliance issues.
Many state agencies promote regulatory compliance through voluntary programs that provide instruction on how to implement an EMS and encourage participation in a range of recognition programs. For example, Indiana sponsors the Environmental Stewardship Program (ESP) and a Governor’s Award for Pollution Prevention. These are separate programs, but both are intended to recognize regulated entities that go above and beyond current environmental regulations.
Applications for these programs can be tedious and time-consuming and can get lost in the shuffle of your other daily routines and responsibilities. Cornerstone’s team can assist in exploring these state-specific recognition programs and, after working with your team to determine which program best fits your needs, scoping the project to keep it manageable. Additionally, we can assist in completing and submitting the application for a recognition program in your state.
Our Division of Quality Management Services has decades of experience in every aspect of developing an ISO 14001 EMS as well as other comparable programs. In addition to full-service implementation consulting, we offer the following services:
Aspects and Impacts – Conduct onsite evaluations and written findings.
Policies and Procedures – Drafting and oversight of policies and procedures.
Application Submittal – Completing and submitting applications for approval.
Audits – Conducted at specified intervals for program compliance by a third party.
Projects – Sustainability projects with carbon footprints, energy audits, waste to energy, and solar.
Contact Cornerstone for support in meeting your Environmental Recognition Program and be the leader in your state.
Bill Hess is Cornerstone’s Manager of Business Development, Northern Midwest Region. He has been on a career path in Sustainability for more than 40 years and just celebrated 22 of those years with Cornerstone. He specializes in ensuring our clients have the resources they need for Environmental Management, Safety Culture Improvement, Loss Prevention, ISO Services, Safety Training, Industrial Hygiene Services, and SDS (MSDS) Management.
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Making the P2 Connection with the FOUNDATION Product Approval Module
Passage of the Pollution Prevention Act by Congress in 1990 was intended to focus industry as well as the U.S. public on efforts to reduce the amount of pollution being generated across the country.
The law gave the United States Environmental Protection Agency (U.S. EPA) the responsibility and the authority to develop and implement a source reduction strategy. As a result, EPA worked to integrate Pollution Prevention (P2) practices into general industry and reduce pollution “at the source” and not at the tailpipe, outfall, or landfill. The Act also required that EPA collect and disseminate information related to P2 to the public.
After passage of EPA’s mandate, each state then implemented its own P2 program which the federal law required to be as or more stringent than the program implemented by EPA. In the early 1990s, Indiana, for instance, adopted a very narrow definition whereby true Pollution Prevention could only be achieved through process change, in-process closed-loop recycling, or input substitution.
Using Indiana’s model as an example, the state’s goal was to reduce pollution through improved efficiency, recycling/reusing waste before it could be sent to a landfill, and by making changes to the raw materials used in the manufacturing process (input substitution). By focusing on the raw materials used in, or incidental to, production, a facility could identify less toxic materials to facilitate more environmentally safe production processes.
How can Cornerstone help your facility improve its P2 performance?
In the early 1990s, Cornerstone developed a chemical inventory system to analyze and track the chemical composition of materials used in production and manufacturing. Over time, Cornerstone’s chemical inventory system was further developed by adding SDS management to create the current FOUNDATION SDS Management and Chemical Inventory System. In addition, FOUNDATION determines the applicability of substances to the Emergency Planning and Community Right-to-Know Act (EPCRA), Clean Air Act, and OSHA regulations to help ensure continuous compliance.
While working with IDEM (the Indiana Department of Environmental Management) during the development of its P2 program, Cornerstone introduced me to the methodology of using a chemical inventory system to assist with Input Substitution. It seemed like the perfect tool to support P2 efforts through the identification of materials that could be substituted thereby protecting the environment (i.e., P2) and creating safer workplaces.
What can FOUNDATION’s Product Approval Module do?
The Product Approval Module in FOUNDATION enables users to fully evaluate and approve (or reject) materials to be used in their operation. The regulatory lists reviewed range from EPCRA, HAPs, Proposition 65 Chemicals, Carcinogens, Reach, ROHS, and can also incorporate customer-specific restrictions and chemicals of concern. Candidate lists are generated for each applicable regulation to which a chemical is subject. The Product Approval Module is also useful in compiling information for ESG (Environmental, Social and Governance) reporting related to customer requirements.
If a team of individuals is responsible for approving materials to be used in production, Cornerstone’s IT team works with the client to create a fully customized Product Approval system which enables mutual review, evaluation, and approval. A streamlined online approval process such as this eliminates delays in review and ensures a holistic approach product review.
Further Information
For more information or a webinar on our Product Approval system, please contact Cornerstone or your Sales Representative.
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Cornerstone's Waste Services Support RCRA Compliance
Many organizations are subject to the requirements outlined in the Resource Conservation and Recovery Act (RCRA), yet they do not know if they are compliant. Cornerstone offers a variety of waste services to assist our clients in understanding their regulatory obligations, identifying areas of non-conformance, and developing a facility-specific plan to maintain compliance. Our goal is to ensure that compliance is not only met, but sustainable. Two of the services we offer can assist you with both, the Hazardous Waste Compliance Assessment and the Waste Compliance Program. There are a number of differences between these services. Our team of experts will work with your organization to guarantee your specific needs are met.
Hazardous Waste Compliance Assessment
Hazardous Waste Compliance Assessments are most beneficial to facilities with multiple hazardous waste streams. A Cornerstone waste team member will conduct a detailed review of your operations and practices to determine the status of compliance with applicable RCRA regulations. Specifically, labeling, storage, container management, disposal, recordkeeping, and reporting. These particular areas can lead to significant penalties if discovered during a regulatory inspection. Our Hazardous Waste Compliance Assessment is a proactive step to identify areas of gaps in compliance.
Waste Compliance Program
The Waste Compliance Program is a facility-specific program designed to provide clients with detailed information about their waste streams, applicable compliance requirements based on their generator status, and supporting documentation for maintaining compliance. This service is particularly useful for plants that are not sure how to manage their various waste streams. Even Small Quantity Generators (SQG) and Very Small Quantity Generators (VSQG) can benefit from this program since many sites do not receive the necessary guidance to fully comply with applicable regulations.
The Waste Compliance Program goes beyond the assessment and provides an actionable written plan with both required and recommended best practices to manage your waste streams. Based on the waste streams at your facility, Cornerstone will confirm that the necessary practices and procedures are in place to comply with regulatory requirements. The site-specific evaluation includes a thorough look at hazardous waste, non-hazardous waste, universal waste, used oil, and recyclable materials. The program provides information, tools, and resources to achieve and maintain compliance with generator requirements.
A Necessary First Step
With the current emphasis on Environmental, Social and Governance (ESG), many corporate executives understand the need to go beyond environmental regulatory compliance to satisfy stakeholder expectations. Their EHS Managers are being tasked with finding sustainability improvements including the evaluation of waste streams and identification of recyclable materials. Cornerstone’s Waste Compliance Program provides the necessary baseline information to move towards the Environmental Pillar of ESG. The identified processes, waste streams, and current disposal practices can then be used to identify targets for disposal alternatives, including waste to energy, reuse, recycling, and zero waste goals. Developing accurate baseline information for waste streams is the first step in determining realistic reduction goals and sustainable goal development. You cannot manage what is not measured.
Further Information
Contact us for more information on waste services that will benefit your organization.