A lot of people—maybe you’re one of them—put off going to the doctor for a checkup, an annual physical, or one of those screenings or tests that are so important as you get older.
It’s understandable. There’s a fear of finding out there’s something wrong, a comfort in not knowing. But avoiding the test can allow a medical issue to get even worse.
It’s the same at your facility. Even if you think everything is running smoothly, there may be issues in your processes, facility layout or features, equipment, or practices. These unrecognized issues can quickly turn into expensive liabilities.
At Envision Environmental, Inc., we offer evaluations to uncover these issues. With our help, you could significantly reduce future liabilities, exposures and risks.
Here are some things you should know about our process:
- You might feel like “it ain’t broke,” so why fix it? After all, your facility hasn’t had any incidents. But that’s why we call them Invisible Environmental Gorilla Evaluations.
- Invisible Environmental Gorillas are issues you can’t see that we, with 20+ years’ experience in environmental consulting, can spot immediately. It’s not your fault. You’re comfortable. You have a routine. You are familiar with your facility and processes. But that means your capacity for observation goes out the window.
- You might say, “Hey, we’re in compliance.” But a facility could be 100% in compliance and still have significant issues.
- You’d rather not face the hassle and expense of a cleanup effort if an issue is discovered. But it’s much cheaper to take care of something now, rather than letting the problem escalate into a more costly issue.
Also, you should know that our recommendations can often be incorporated into your preventive maintenance program to save you time and money.
Some Common Invisible Environmental Gorillas
Based on our experience and the hundreds of assessments we’ve done at facilities around the country, we’ve identified several common problem areas.
1. Where Do Your Recycled Materials Really End Up?
If you recycle the containers (steel drums, cardboard boxes, etc.) that deliver materials to your facility, you could be setting yourself up for a six- or seven-figure problem in the future… if you don’t take one simple, but vital step:
Remove the labels from these containers that have your facility/company name on them.
Some recyclers may sell off containers to another company instead of properly recycling them. What happens then if that company then fills them with something hazardous, and dumps them?
If they’re found, and your name is still on them, who do you think is going to get the call from regulators?
2. Where Does that Floor Drain Go?
Just about every facility has floor drains. You might assume they discharge to the sanitary sewer system. But have you ever checked?
We’ve seen issues with drains in new construction, and in 100-year-old buildings. Some drains do go to the sanitary sewer, but we’ve seen others that go elsewhere; like to on-site septic tanks that no one knew about or to off-site retention ponds.
Sometimes these drains go nowhere because the building contractors never connected the drains to a sewer line when the building was constructed, which means contaminants have been going straight into the soil and groundwater beneath your facility.
We recommend that every facility have a map of its floor drain locations and identify where all of these drains discharge. If you don’t have one, we can easily create one using a utility locator.
3. Storage and Good “Housekeeping”
Interior and exterior storage areas can be major problem areas. But you can follow some simple rules to cut your risk:
- Keep storage areas neat and well organized.
- Keep containers tightly closed.
- Make sure all containers are correctly labeled.
- Most important, always store compatibles with compatibles.
That last point brings to mind a retirement community development we inspected a few years back.
The development had a nice indoor pool and the pool chemicals were stored in a metal cabinet in the pool filter room. The problem is, the vapor from the liquid chlorine degrades metal. When we opened that storage cabinet, we were surprised the severely rusted metal shelving was still supporting those 30- or 40-pound buckets of chlorine.
With that level of degradation, anybody opening the cabinet risked the shelves failing and dumping liquid chlorine all over them. Quick tip: store chlorine on plastic shelving.
At your facility, you’re probably focused on your storage tanks and drum yard—and rightly so. But don’t forget to check out something as simple as a janitor’s closet.
Don’t keep bleach with any drain cleaners or similar chemicals. A mixture of the two can generate lethal gas. Also, acids and bases should not be stored with water-based material. If water is added to either an acid or base, the mixture can boil up and splash out of the container—very hazardous!
4. Extra Steps to Take with Outside Storage
When you store material outdoors, you must take into account the effects of weather.
Take, for example, a dumpster full of scrap metal. The scrap metal usually has a fine coating of oil on it. If that dumpster is not completely covered, water will get in when it rains. That rain will then come in contact with the scrap metal and will wash the oil off. The resultant oily water could drain into a pond or drainage swale, and possibly offsite, impacting your neighbor’s property.
A few weeks back, we did a walk-through of a facility and spotted one of the most insidious Invisible Environmental Gorillas for outdoor storage we’d ever seen. The company couldn’t understand why their stormwater catch basins weren’t draining. The culprit? Right near the basins, they stored bags of cement mix, many of which were ripped. Every time the wind blew, that cement mix dust drifted into the catch basins. What happens when cement mix gets wet?
Make sure you cover or protect your outdoor storage areas from weather events!
5. Other Pathways to the Environment
Floor cracks, floor seams, and floor joints that aren’t sealed are some of the most common Invisible Environmental Gorillas. These are direct pathways to the environment. Anything released in your facility near one of these Gorillas has the potential to impact the soil and groundwater below your building.
When we point this out to our clients, they’ll usually go ahead and seal them. But when we come back to the facility, we often notice that the repaired crack or floor joint has opened up again. What happened?
The facility used a sealant that was incompatible with the materials stored (and thereby released) in the area… and they dissolved the sealant.
6. Operate and Maintain Equipment Correctly
When it comes to the equipment at your facility, you must:
- Operate machinery according to the manufacturer’s specifications.
- Use the right spare parts.
- Follow the manufacturer’s recommended maintenance schedule.
A couple of bucks saved now on off-brand parts could lead to machinery that breaks down well short of its potential lifespan, or serious environmental impact from a malfunctioning piece of equipment down the road that could lead to a six-figure remediation effort. We’ve seen such incidents occur many, many times at facilities.
7. Improper Practices and Policies
When we do facility evaluations, key elements we look at are the environmental, health and safety programs that a facility possesses, such as a spill response plan and emergency response programs.
The most important part of these plans is the contact hierarchy, which tells you who to contact in case of an emergency condition. We often find the contact hierarchy to be outdated. The facility personnel listed as emergency contacts do not work at the facility anymore, or phone numbers/e-mail addresses are incorrect. Under such conditions, employees don’t know who to call; it’s like you don't have a plan at all.
Another issue we see at facilities is that the responsibilities of environmental, health and safety team members aren’t well defined in the emergency plan. It’s not clear who does what, when it gets done and how it gets done. This impedes effective response.
Let’s Start Finding Your Invisible Environmental Gorillas
It still might be hard for you to believe, but there could be issues at your facility that you haven’t recognized that could cause you significant exposures and liability.
As outside observers, we can spot these issues quickly.
Our process is to first identify potential liabilities and then make recommendations to address them and to keep them from recurring in the future. We do charge a fee for our evaluation and we develop a program to address the identified invisible environmental gorillas that you can implement in-house or if you prefer, with our assistance.
In any case, we recommend that our clients integrate this work into their own preventive maintenance programs—these gorillas can easily become invisible again and come back to haunt you!
There could potentially be Invisible Environmental Gorillas at your facility right now. We’d like to help you find them. A great first step is to download our free guide: The Top 10 Environmental Gorillas Checklist.
Read through it and take a hard look at your facility with fresh eyes. You’ll be surprised by what you may see.