If you’re the property or facility manager at a hotel, you have a lot to worry about. Guest safety is huge. There are a lot of maintenance requirements inside and outside. And the larger the hotel - and maybe even add in a conference center or events space - the more there is to keep track of.
But that doesn’t mean you can forget about some basic environmental issues that could land you in hot water if there is a release into the environment, or if you simply don’t follow key regulations, secure necessary permits, or put your staff through required training.
Here are some of the most common (and often overlooked) environmental issues at hotels.
When serious weather strikes, back-up generators keep your hotel up and running when the power goes off. You need lights on, freezers running, etc. to stay operational and sometimes provide a safe refuge.
But you can’t just forget about your generator, as well as its fuel storage tank, until it’s time to start it up. Depending on its location, size and fuel source, your back-up generator may require an air permit. If the back-up fuel for the generator is fuel oil, which is usually stored within or near the generator in an aboveground tank, this may also trigger the need for a spill management plan, a.k.a. Spill Prevention, Control, and Countermeasure (SPCC) Plan, as well as related training for anyone working with the generator, especially the guy who fills it up with fuel. If you have the capacity to store 1,320 gallons or more of oil above ground, you may need to have an SPCC Plan.
But even if you don’t meet this threshold, we always recommend you develop an SPCC Plan if you have a generator that uses fuel oil. First, it significantly reduces potential exposures. Second, insurance companies love when you have a spill plan in place, and you could see savings on your rates. Not to mention SPCC Plans are now pretty easy to implement. The USEPA has all the information you need on their website. Download the SPCC Plan template found on the USEPA’s website, fill in the blanks with information specific to your facility, and implement the plan.
Do you have a restaurant in your hotel… or a large commercial kitchen providing meals for banquets and other events? That’s a red flag for another major environmental issue due to cooking oil and grease, which need to be properly stored and disposed of.
The reason cooking oil and grease are taken so seriously is that in recent years, so-called “fatbergs” made up of congealed oil and other materials have been clogging up sewer systems. As a result, regulators are keeping a close eye.
Many local sewer authorities are implementing new rules and regulations concerning the discharges of fats, oils and greases (FOG) to their sewer systems, and in some cases the sewer authorities are requiring permits if you have the potential to discharge FOG. At a minimum, you should make sure you have a grease trap installed in the sewer line wherever you generate FOG, and make sure you properly maintain the grease trap by cleaning it out on a routine basis. And don’t forget to document every time you pump out your grease trap because your local sewer authority will request that type of documentation from you.
Remember we mentioned that if you have the capacity to store 1,320 gallons or more of oil aboveground at your facility, you may need an SPCC Plan. This federal requirement applies to oil of any kind, not just petroleum-based oil. It also applies to your cooking oils. As a result, we often find that some hotels require SPCC Plans due to the amount of aboveground oil storage capacity they have at their properties. So, check to see if you meet the requirements for needing an SPCC Plan.
Where Do You Put Universal Waste and E-Waste?
You have hundreds of rooms in your hotel. Maybe some large ballrooms. That’s a lot of lightbulbs you’re changing every year. But what do you do with the old ones? How about all the worn-out batteries for the TV remotes and other gadgets in the rooms?
These items are considered to be universal waste – which actually contain hazardous waste – and must be properly stored and then taken offsite by a licensed recycler or disposal company. Same with any old TVs, computers, or other e-waste. You can’t just throw it all in the dumpster.
Be sure to do your due diligence on any recycler or disposal company. Make sure the waste is properly stored and disposed of or recycled when taken offsite. As part of your due diligence, you should check if the recycling company has any violations on record, that they’ve maintained good compliance history with regulators, that they have sufficient insurance coverage, and that they have the proper permits.
It also pays to make sure they are financially sound. Run a Dunn and Bradstreet report on them. It may cost a few hundred dollars, but gives you real peace of mind. If they go out of business and your waste is in their facility – you could be in real trouble.
You may not be aware, but that material is still your responsibility when it’s offsite, no matter what certificate your provider issued you when they took the waste. If regulators find a pile of your old lightbulbs in some random warehouse… they’ll be talking to you as the “generator” of that waste. So, make sure the firm tells you where your waste is going, how it is getting there, how it is being handled/treated, and provides you with a certification that all measures were completed.
Many hotels have swimming pools. Sometimes multiple pools… even water slides and lazy rivers. Great fun for visitors. But these are all a source of concern for facility managers due to all the chemicals used in the upkeep. We’ve done a few invisible environmental gorilla evaluations at nursing homes with pools, and no doubt some of the same issues exist at hotels.
First, we’ve seen chemicals like liquid chlorine – a hazardous chemical – stored on metal shelves that were corroding. Chlorine tends to deteriorate metal shelving. In the event of a collapse, the splash could seriously injure somebody. Store these corrosive materials on sturdy, well-constructed plastic shelving. Anybody who uses those chemicals regularly should also be properly trained and have protective equipment like safety glasses and gloves available at a station in that room. In some cases, a respirator might be appropriate.
The pool guy at your house might show up in a tank top and flip flops, but these chemicals are serious business and could present safety issues for your staff or guests. One quick example from my personal experience…
I recently replaced the sand filter on my home pool with one that uses diatomaceous earth because it’s more efficient. It’s a fine, powdery material. And there’s a big warning on the bag that says not to breath this stuff in. But not many people read those fine print warnings, do they? If you’re a facility manager, you definitely should.
What’s “Under” Your Elevators
One of the first places we look for potential liabilities in multi-story buildings, including hotels is the base of the elevator shaft. Often, we find a lot of muck, gunk… and water. This water is often found to be groundwater, which means there is an integrity issue, a crack in the base of the elevator shaft that is allowing groundwater to seep in. And if water is getting into the shaft, whatever material is released into the shaft, like hydraulic fluid from the elevator equipment, can exit the shaft in the same cracks and impact the environment.
We recommend that whenever you are getting your elevators serviced – which is required on a routine basis to make sure the mechanisms and safety equipment are in good working order – that you also check out the shafts, and keep them clean and debris free.
Forklifts and Aerial Lifts
As a busy hotel, you probably have forklifts down at the loading dock to receive deliveries. If you have a conference center, it’s probably even busier. And to hang up displays, change lightbulbs in high ceiling areas, and do other maintenance and set-up work, you probably have some ladders and aerial lifts. That brings up a few issues.
First, all employees working with that equipment must have OSHA-approved training to work with such equipment, even if it’s just how to properly use a ladder.
Second, watch out for those forklifts. If they are battery operated, those big lead-acid batteries can be dangerous. You see, if you have any hazardous materials at your facility and those materials are over a certain threshold, you may need to report those materials to local and state officials via the Community Right-to-Know Act. And before you say, “We don’t have hazardous material,” you probably do.
For example, if you have battery-operated forklifts you use to bring in deliveries, you may have to report the lead and acid content of the batteries to state and local officials if it’s over a certain threshold, so they know what they’re dealing with if there is ever an incident at your facility. You also need safety data sheets, as well as proper training for the forklift operators. This is one of the biggest violations we see right now.
Also, with forklifts, you probably have an outside firm that comes regularly to service the equipment. Where do they do that maintenance? If it’s in your back parking lots, as I’ve seen on many occasions because I’ve seen the stains on the ground, that’s not good. The released materials could get into a stormwater catchbasin and impact a surface water body. Any service should be done in a controlled environment. And any waste that they take away… make sure it’s properly disposed of.
Every hotel has cleaning supplies and maintenance storage areas, usually several in multiple locations, used for storage of cleaning supplies and other items. There are chemicals and materials in there you don’t want to mix together. Be sure to store compatibles with compatibles and keep the area neat, clean and well organized. Keep containers tightly closed. One last thing - make sure the label on the container matches the contents. You don’t want to be left wondering what’s in there.
Also, make sure you have designated areas to store your waste materials in preparation for offsite disposal/recycling, especially your hazardous wastes, such as universal wastes. These areas must be properly maintained and all storage containers properly labelled.
Although by regulation your hotel may not require a state-issued stormwater permit, don’t think you are in the clear when it comes to stormwater issues. Don’t forget about your local regulators.
If you store containers outside, like dumpsters or roll-off boxes, they are exposed to the elements, and may be a source of contamination due to stormwater coming in contact with materials in the dumpsters and the resultant runoff. As a result, many local regulators have implemented exterior storage requirements to safeguard against stormwater pollution for facilities that are not required to have a stormwater permit.
Often this issue comes into play during construction or renovation work, where you could have many construction dumpsters staged outside with waste. Many local regulations require all dumpsters and roll-offs to be covered to prevent stormwater contamination issues. Make sure you review your local regulations as it pertains to exterior storage requirements.
That’s Just the Start
I’ve gone over several of the major potential environmental liabilities you might have at your hotel right now. But that’s not all by a longshot. Cleaning supplies, noise regulations, storage and servicing of maintenance and landscaping vehicles and equipment (and the fuel they use)… those are just some of the other issues you could be facing at your facility.
Often, these issues are “invisible” to facility managers and others who’ve been onsite for a long time – it becomes part of the scenery. Or there’s an attitude that it’s always been that way… so it must be okay.
I’d invite you to go over this list to see where you might be falling short. I’d also be happy to do an evaluation for you or discuss any critical issues with you. But first, let’s do a free consultation to see how my team and I can help.
Please contact me, Mark Roman, at 609-208-1885 or via email at firstname.lastname@example.org.