It’s a nightmare scenario for any facility manager.
You’ve prepped for months for a major capital improvement that will expand your operations – and hopefully boost profits.
Executives and bigwigs from around the country are flying in for the ground-breaking ceremony.
Then, the day before or the day of… or maybe a few days later, all work must stop.There are a variety of reasons, which will go into in just a moment, but the root cause is that you didn’t get your environmental consultant involved early enough in the process.
Take for example one site we worked on a few years back. They had hired the contractors for a major building expansion. They broke ground and… hit previously unknown underground storage tanks.
Work was halted as the tanks had to be removed and surrounding soil contamination remediated. The expansion was delayed for more than a year. And since they had hired the contractor, they had to pay them.
Here the problem is a lack of facility knowledge and no grounding in property history, two of the Core Four Requirements for a smoothly running facility.
If we had been brought in during the planning phase we would have reviewed old plans, aerial photos, and drawings; looked through old records; and checked files from regulators.
No doubt those tanks would have shown up, and they could have delayed construction or changed their expansion plans. Much more cost-effective.
Permits generally last for about five years. But they only cover the activities that were on the original application.
If you make even seemingly insignificant changes to the raw materials you use, the waste that is generated, where you store materials, the layout of your facility, or additional production lines that boost your output, or whatever else… you most likely have to modify your permit or get a new one.
The right time to find this out is before you put the time, money, and effort into a capital improvement. Not when a regulator comes in for a surprise inspection and finds you in violation… or you can’t get a building permit issued.
A thorough evaluation from your environmental consultant will let you know whether you’re good to go permit-wise or what you need to do to stay in compliance.
We had one client that manufactured cosmetics for several different companies. In this industry, the product “recipes” are always changing. As a result, the raw materials are always changing. Problem is that their air permit was only valid for the materials used when they first applied.
In another recent case, we met with a frantic client. We’d been bugging them about advising us of their plans for a massive upgrade to their facility. But they’d waited a couple of weeks before breaking ground and really only gotten in touch because the local government wasn’t issuing them a building permit… until they got a new wastewater permit from the state.
This particular facility did its own wastewater management. And the upgrade involved putting a bunch more wastewater into the system. That triggered the need for a permit modification. Now they’ll miss their target kick-off date for construction.
Again, it could have been avoided if they had called us a months ago and informed us of their specific plans. We would have known that a modified permit was needed and secured well in time for construction to begin.
When a facility is put up for sale, unless it is being sold “as-is,” a smart buyer typically wants to do an investigation of the entire property before signing a contract.
This due diligence process starts with a Phase 1 Environmental Site Assessment. Done correctly, this investigation should identify potential risks and exposures and highlight areas in need of further investigation. (See our previous article on what an effective Phase 1 Assessment looks here.)
If something is found, buyer and seller work out a deal, either the sale is contingent on remediation being done or there is some sort of price reduction. Sometimes the deal falls through altogether.
As the seller you don’t want to be taken by surprise in a scenario like this. Ideally, you would have taken care of any issues in order not to hold up or impact the real estate transaction in any way. It’s like fixing up the air conditioning or putting in a new roof before you put your house on the market.
In this case, you would “pre-empt” the buyer’s Phase 1 Assessment by hiring an environmental consultant to do one for you.
This due diligence would include a thorough investigation of the site itself, no stone left unturned. A qualified environmental consultant would also do a thorough review of regulatory files and in-house records, aerial photos, drawings, and more to get a sense of property history. They would also speak with key personnel, especially veteran employees, to get more clues about potential problem areas.
It’s tempting to just not think about these possible liabilities on your site. But it’s much better for you to find them now, rather than wait until a buyer finds them.
As a facility manager you always have an eye on the bottom-line (and management does too). It’s tempting to only call an environmental consultant in when there is a dire need or emergency – see examples above.
That’s a big part of our job. But putting out fires is not the best way to use environmental services by any means.
And in many cases, being proactive with site monitoring, permit management, and the impact of site changes by being in close contact with your environmental consultant can forestall a lot of problems.
You’re busy with the day-to-day operations. By staying in touch with us and keeping us informed of your plans we can foresee – and head off – potential problems before they turn serious. Certainly call us as soon as you have capital improvements or other projects in the works. We can keep your capital improvements on schedule and your permits correct.
The best outcomes are when the same environmental consultant is on board from early on. When we have a solid foundation in your processes, how you store waste, the history of the property, and other factors, we can more easily recognize when something is out of place.
Consultants who come in fresh, especially in emergency situations, have to start from scratch in their investigation. Someone familiar with your facility can hit the ground running.
You might not think you need an environmental consultant right now. But I’d invite to be proactive in identifying risks and exposures at your facility. Use our Top 10 Environmental Gorillas Checklist to find environmental issues hiding right under your nose. (In my experience, they’re always there.)
You can download this checklist for free here.