I always love the beginning of the year. On a personal level, it’s a chance to work towards a new you by getting in shape, ditching a bad habit, or whatever your goal may be. It’s a fresh start, a clean slate.
But I’m going to recommend that you, as a facility manager, also take this opportunity to get your site’s environmental, health and safety situation in shape, too.
Even if you think things are humming along smoothly, it’s always been my experience that, over time, issues do come up and can quickly become serious if not addressed early. Preventative and proactive measures are also often lacking.
Here are a few things you can do at the start of the year to get a fresh start – and head start – on conquering known and so-far-unknown environmental, health and safety issues at your facility.
1. Refocus EH&S Strategies and Policies
As a facility manager, you’re so busy that your primary focus is the here and now, including compliance with regulations. You feel like that’s all you have time for. But, a good EH&S policy is about more than just following regulations.
Beyond compliance, there could be EH&S issues that will take significant effort and cost to address if overlooked. Compliance is simply not enough. You have to be aware of and understand everything that is going on at your facility – past, present and future.
Yes, concentrating on the present is important, but you also have to look to the past. Don’t repeat mistakes! Understand your property’s history and learn from it. With that knowledge, past and present, you can then look to the future as you put together a plan to identify potential exposures at your site and manage your liabilities.
Also, don’t just mind your own business. Keep an eye on what your neighbors are up to, and what their history is, because it can affect your site.
2. Commit to the Core Four
To have a solid foundation for a productive, safe, sustainable, and profitable facility, you need to master the Core Four:
Property History – Your facility’s past will affect its future. It impacts your planning, environmental programs, contamination remediation, assessments, and more.
Communication – You want to make sure everybody is on the same page about your environmental, health and safety programs and any regulations that must be followed.
Facility Knowledge – You must know your raw materials, the finished products, and the waste products generated. In other words, what you do and how you do it.
Documentation – Detailed recordkeeping is key in addressing environmental issues and future planning, as well as maintaining property history.
Combined, these elements give you a dynamic and effective look at where you are and where you’re going and are essential to running an efficient and profitable facility.
3. What Were You Up to Last Year?
Now is the time to review the current state of your operations, as well as your operations in the past year. Specifically, what changes have occurred… and how those changes might affect your permits and compliance with regulations.
Remember, when you get a permit, it reflects only what’s happening at that specific time. But processes, raw materials, and other factors change. So evaluate your permits to make sure they are still valid in light of your new process(es). In some cases, they need to be modified… or even a new permit issued.
Keep in mind that regulations also change, so it is important that you know what changes have occurred and if those changes affect your facility. This is a common issue for many of us. Afterall, who enjoys checking up on and reading regulations? The last time you checked regulations may have been a few years ago. As a result, a regulation that may not have been applicable to your facility, may now be. Get online to check, or contact industry associations to review any regulatory changes to see if you’re still in compliance; you might be surprised.
4. Improvements Ahead? Do This First
At the beginning of the year, most facilities have a veritable menu of capital improvement projects on the calendar. But I’ve seen too many of those projects get stalled. The biggest hurdle is EH&S issues. That’s why it’s so important to make sure you get involved with any capital improvement project early in the process. This way, you can ensure that all EH&S issues are addressed; are up to date; and necessary permits, programs or policies are in place in order to avoid any delays or bottle necks.
The last thing you want to do when the president of the company is ready to cut the ribbon on a new production line is to realize that you need a new permit before it can get up and running.
An essential, but often neglected, part of compliance is required regulatory training. Regulatory required training usually needs annual refreshers. So now is a perfect time to review training requirements and figure out who needs to be trained in what… by when. Get your training schedule developed now.
6. Download and Review the OSHA Top 10
Every year, OSHA publishes its list of the Top 10 Most Frequently Cited Violations. Download the latest version and then use it as a checklist throughout your facility. Make sure each of those items is thoroughly addressed.
If you’re ever inspected, the OSHA inspectors will look at those most common violations first. If you’re in good shape, the rest of the inspection will more than likely go smoothly. If not… OSHA rolls up their sleeves and goes over the rest of your facility with a fine-toothed comb.
7. What Are Your Environmental Gorillas?
Overlooked environmental gorillas are those EH&S issues that, because you’re at your facility day in and day out, you just don’t see… but an outsider can easily spot. Simply put, you just get used to how things are and don’t realize there’s a problem. Overlooked environmental gorillas often lead to some costly issues if you do not identify, manage and eliminate them.
The most common places we see environmental gorillas are:
- Trenches and pits – Keep them clean and inspect them for integrity issues.
- Floor drains – Should be clean and neat, and you must know where they discharge.
- Interior storage areas – Keep these areas well organized, and clean. Store compatibles with compatibles. Containers should be labeled with current contents and tightly closed. Flammable containers should be properly grounded – verified by a licensed electrician.
- Exterior storage areas – Same rules as interior storage areas apply. But you must also account for weather conditions. When it rains, where does the water that comes in contact with your stored materials drain to? Do you need permits for outside storage of that material?
- Elevator and hydraulic lift shafts – Many of us have these structures at our facilities, but very few of us ever inspect them for structural integrity. Keep them clean and debris free – they are potential pathways to the environment.
- Your roof – Very few of us routinely inspect our roofs. The only reason we may check the roof is if it is leaking and we are looking for the source of the leak. Make it a routine to inspect your roof for foreign materials (oil, staining, debris, etc.) – for things that should not be there. Keep in mind that any foreign material, debris, residue, or oils on the roof will eventually make their way to the ground surface, potentially impacting soil and water. And, these issues could be a sign of major problems at your facility.
- Old equipment and more – That old machinery you have shoved in the corner – was it properly decommissioned… would moving it cause a major EH&S problem? What’s in those barrels that have been in “long-term” storage? Do they contain waste materials that need to be properly disposed of?
As you identify your facility’s overlooked environmental gorillas, manage them and eliminate them by keeping everybody informed and then include them in your ongoing preventative maintenance routine so they don’t come back and cause you more problems.
8. Emergency Planning
By March 1 of every year, facilities are required to report hazardous materials above certain thresholds as part of the Emergency Planning and Community Right-to-Know Act. This information is sent to federal, state and local officials, including police and fire departments and emergency planners.
You might say, “I’m not a manufacturer… I don’t have hazardous materials.” But, for example, if you’re a warehouse and have enough battery-operated forklifts (or other battery-operated equipment), you may need to report the sulfuric acid and lead content in those batteries. Make sure you know what hazardous materials are at your facility and how much is typically stored onsite.
9. Local Regulations
You might think that if you have your state and federal permits and are adhering to those regulations, you’re all set. But don’t forget to monitor what your local regulatory body requires. It can vary significantly. This is especially important if you have facilities spread out across multiple municipalities.
Looking to the Next Year
There’s no time like right now to examine your environmental, health and safety policies and procedures to see where you need improvement. Take this opportunity to reduce your exposures and liabilities. Some simple proactive steps now can save a lot of hassle and money later. And don’t forget, being in compliance is just not enough.
If you’d like further recommendations on your upcoming EH&S review or your assessment brought something up that you need help with, please call me now at (609) 208-1885 or email me at email@example.com to schedule a phone consultation.